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r <br /> August 24, 1990 <br /> Mr. Val F. Siebal <br /> Mr. Ronald L. Valinoti <br /> Page 3 <br /> of the site would be impaired by a finding as alleged in the RAO <br /> and as such is contrary to policy and Federal preemption law. <br /> For all of the above reasons, which are not claimed to be <br /> exhaustive, respondent denies liability in whole or in part for <br /> the actions claimed in the RAO and places in issue all such <br /> claimed liability. <br /> Respectfully submitted, <br /> LAW OFFICES OF <br /> DARY B. KATCHER <br /> DARYL B. KATCHER <br /> Attorney for Robert E. Kupka <br /> and Lodi Airport Management <br /> Corporation <br />