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+ J <br /> y�-1LAW OFFICES <br /> SAN jOSE HAROLD ROPERS - F ,1 MAJESKI, KOHN, BENTLEY, aO NORTH OFFICE <br /> STREET <br /> (1904-!9561 .7 (y N+�.�` <br /> s I.Ini WAGNER Vl K�1SAN JOSE,CALIFORNIA 95113LAW pFFICE$bF Rte. TELEPMQNE{4001287-6252 <br /> RON W.FIELDSFACSIMILE(408)297-6019 <br /> G70 HOWARD STREET A PROFE5510 NAL CORPORATION <br /> SAN FRANCISCO,CALIFORNIA 94105 SANTA ROSA OFFICE <br /> 1-9 rr,� r,r� ��,t I. I [ 1001 MARSHALL LL STREET <br /> 1 l 1 1 Cl 3558 ROVNf1 BARN BOVLEYARO,SUITE 300 <br /> L05 ANGELES OFFICyE�. �, _I REDWOOD CITY. CALIFORNIA 94063 SANTA ROSA,CALIFORNIA 95403 <br /> 5SO SOUTH HOPE STREET,SUITE 1900 TELEPHONE 1707)S24-4200 <br /> LOS ANGELES,CALIFORNIA 90071 TELEPHONE (4)5) 354-8200 FACSIMILE(707)523-4610 <br /> TLLE PHONE 12131312-2000 FACSIMILE (415) 367-8643 FricE <br /> FAC51MILE(213)312-2001SACRAMETo <br /> FACSIMILE (415) 367-0997 1000GSTREET,SUITE 400 <br /> SAN FRANCISCO OFFICE SAC RAMENTO,CALIFORNIA 95814 <br /> 570 HOWARD STREET TELEPHONE(916)556-3100 <br /> SAN FRANCISCO,CALIFORNIA 94105 FACSIMILE 1916)442-7121 <br /> TELEPHONE 1415)543-4000 <br /> FACSIMILE{415)512-1574 <br /> ROBVRT P.SORAN September 18 , 1994 <br /> Mr. Michael Collins <br /> San Joaquin County <br /> Environmental Health Division <br /> P.O. Box 2009 <br /> Stockton, CA 95201-2009 <br /> RE: Ryan Mobile Home Park, 355 E. Louise Ave, Lathrop <br /> Dear Mr. Collins: <br /> As you may recall, I recently had the opportunity to meet <br /> with you and review the file for the above-referenced property. <br /> At that time you noted that the county had not added Mr. Fuller <br /> as a responsible party (RP) due to the fact that Mr. Ryan was <br /> unable to provide evidence of Mr. Fuller's knowledge of the <br /> underground storage tanks. <br /> In order to help facilitate adding Mr. Fuller as an RP, I am <br /> prepared to file a declaration with the county as to my <br /> observations and personal knowledge of Mr. Fuller's statements <br /> during a recent site inspection held at the property with Mr. <br /> Fuller, his counsel, and myself. During this inspection, Mr. <br /> Fuller was clearly pointing out the locations of both underground <br /> storage tanks as well as the location of the pump dispensers for <br /> each tank. Mr. Fuller described the then-existing driveway <br /> access to the property, noting that the trucks would enter <br /> through a driveway located at the southeast corner of the <br /> property, driving straight into the tanks, where fuel was <br /> dispensed directly to the trucks. Mr. Fuller indicated that this <br /> activity was ongoing while he was present at the property. Thus, <br /> the knowledge he disclosed in regard to the tank and pump <br /> location and its use should be sufficient to satisfy the <br /> requirement that he had knowledge of the tank's existence and use <br /> thereof. <br /> Accordingly, we request that you add Mr. Fuller as a <br /> responsible party to the ongoing remediation work, and that you <br /> confirm such with our office directly at the above address. <br />