Laserfiche WebLink
r <br /> In re Interstate Brands Corporation <br /> Case No.04-45816(JWV) <br /> ATTACHMENT TO PROOF OF CLAIM FILED ON BEHALF OF THE STATE OF CALIFORNIA <br /> PURSUANT TO BANKRUPTCY RULE 3005 <br /> This claim is a contingent and unliquidated claim for the cost of the environmental cleanup of <br /> certain property located at 1426 Lincoln Street, Stockton, California(the "Lincoln Street Property"). <br /> This Claim is filed on behalf of the State of California, its agencies the State Water Resources Control <br /> Board,the California Regional Water Quality Control Board, Central Valley Region and its sub-division <br /> the County of San Joaquin("State") by Lorrie L. Greene ("Greene"), a prior owner of the Lincoln Street <br /> Property,pursuant to Bankruptcy Code § 501(b) and Bankruptcy Rule 3005(a). <br /> Greene is informed and believes that this claim arises from the activity of Interstate Brands <br /> Corporation(the "Debtor") as a prior tenant of the Lincoln Street Property, relating to the installation of <br /> an underground storage tank("UST")by the Debtor and the removal of that UST by the Debtor in July <br /> of 1988. Upon the removal of the UST, it was determined that there was evidence of soil contamination <br /> by the presence of petroleum hydrocarbons in soil and ground water samples at the Lincoln Street <br /> Property. Greene is further informed and believes that all such activity regarding the UST occurred prior <br /> to Greene obtaining legal title to the Lincoln Street Property which she inherited from her mother. <br /> This claim has been filed as a result of Greene's receipt from the County of San Joaquin of a <br /> Notice of Responsibility dated November 15, 2005, as a prior owner of the Lincoln Street Property and a <br /> further notification from the California Regional Water Quality Control Board dated September 26, <br /> 2006,that further remediation and monitoring will be required. <br /> Greene disputes any liability for such remediation and monitoring of the site. Greene is informed <br /> and believes that the Debtor is the primary responsible party for the remediation of the site. Greene is <br /> further informed that neither the State,nor any of its agencies or subdivisions,has filed a claim in this <br /> case relating to the remediation of the Lincoln Street Property. Since Greene may be entitled to <br /> reimbursement and/or contribution from the Debtor for any costs that Greene incurs in connection with <br /> this matter, she is thus entitled to file this claim under Bankruptcy Code §501(b) and Bankruptcy Rule <br /> 3005 on behalf of the State. <br /> As the site remediation at the Lincoln Street Property is ongoing, Greene at this time has no <br /> information regarding the scope or amount of any such obligation. <br /> 25099/9999 <br /> 3/27/07/EJT/317924.1 <br />