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v <br /> r" <br /> MULLEN, SULLIVAN SC NEWTON <br /> 4F COUNSEL <br /> THOMAS JNEWTON ATTORNEYS AT LAW - ULLEN <br /> M <br /> CRAIG RASMUSSEN RO8ERT H. UL <br /> STEPHEN C.SNIDER 11H WEST TOKAY STREET C.M."BUD"SULLIVAN <br /> JAMES V.DEMERA ill <br /> P. O. BOX 560 <br /> LO41• CALWORN1A 95241-0560 <br /> (209) 334-5544 <br /> FAX (209) 333-1034 <br /> December 14, 1994 <br /> Mr. Albert M. Ellis <br /> Hakeem, Ellis and Simonelli <br /> Attorneys at Law <br /> 2800 W. March Lane <br /> #200 <br /> Stockton, California 95219 <br /> Re: Giannoni v. .Madison, et al. <br /> Dear Mr. Ellis: <br /> Having received the correspondence from Mary Meays, of the <br /> Public Health ;Services for San -Joaquin County, regarding her <br /> suggestion that you cooperate with the remediation proposed <br /> by my client, Mary Lehr, and having had no response, be <br /> advised that I have no other alternative but to contact the <br /> Central Valley Regional Water Quality Control Board seeking <br /> your client' s designation as a PRP, thus holding him liable <br /> for not only the contamination and cleanup of his property, <br /> but also subjecting him to the iappropriate levy of fines . <br /> It is most unfortunate that we ;have had these unnecessary <br /> delays, in that the property would likely have been cleaned <br /> up by now had we had Mr. Giannoni' s cooperation. Our re- <br /> quest to the Board will be subiitted on December 20 should <br /> your client change his mind about allowing us to proceed <br /> with -the remediation. <br /> I <br /> I remain open to discussion regarding. this matter. <br /> Very truly yours; <br /> 1 <br /> MULLEN, SULLIVAN & NEWTON <br /> by <br /> JAMES V. DeMERA III <br /> JVD:dm <br /> cc: _ Mrs. Mary Lehr <br /> 1, <br /> ' <br /> Ms. Mary` Meays <br /> DEC 15 1994 <br /> ,. �NVIR��MEN�AVIC�AYH <br /> pE�tMti�1 SSR <br />