SITE INFORMATION AND CORRESPONDENCE_CASE 1

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PATRICK D. RIDDLE ATTO R N EY AT LAW 7540 SHORELINE DRIVE,SUITE B STOCKTON,CALIFORNIA 95209 _ (209)952-6262 L F E B 7 -11L 4 I AL HEALTH F-r<W,4,'T/SERVICES January 30, 1990 PUBLIC HEALTH SERVICES San Joaquin County P.O. Box 2009 Stockton, CA 95201 Attention: Jim Miller RE: Collegeville Market & Cafe Site Code: 2259-345 13521 E. Mariposa Road, Stockton, CA 95204 Dear Mr. Miller: As you know, I represent the interests of Abe and Sami Ayesh with regard to the acquisition of Collegeville Market & Cafe which was found to have leakage of the underground storage tanks. This case is in the process of litigation and I am attempting to determine the full extent of damages as a result of the leakage to the underground storage tanks. In order for us to conclude this matter, I need to determine the extent of the underground contamination. For this purpose, I hired Nor Cal and Aaron Swickard to obtain a permit so a site assessment could be completed in order to determine the extent of damages. As yet, your office has refused to allow me to have site assessment permit. You stated that somebody has to accept liability for the UST Pilot Program. Considering this case is in litigation, no one will admit liability or accept the costs of cleaning up until this matter is concluded by the court. Without the county authorizing a site assessment permit, we will not be able to conclude the case, and therefore, no one will ever admit liability nor will a judgment be filed. If we are able to get the permit, then, we can determine the extent of damages and take this matter immediately to arbitration, and thereafter, go to trial, if necessary. At that point, when a judgment is obtained, you will have someone who will have no choice but to be liable for the UST Pilot Program.