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• • P `_ , <br /> «mak -� y/ <br /> CT- <br /> I ROBERT B. ZARO, ESQ. , State Bar No. 83078 <br /> D3 AHUEScripps <br /> AND CALLArive, AM Su <br /> 2 83 Scripps Drive, Suite 200 � <br /> Sacramento, CA 95825 <br /> 3 Telephone: (916) 648-7444 SEP 6 1991 <br /> 4 Attorneys for Defendants and Claimants ENVIRONMENTAL HEALTH <br /> BENNIE HEIN, individually and doing busine!FERMIT/SERVICES <br /> 5 as NORGE CLEANERS and NORGE CLEANING VILLAGE; <br /> and BONNIE K. CROSBY, individually and doing <br /> 6 business as NORGE CLEANERS <br /> 7 <br /> 8 IN THE MATTER OF THE CLAIM OF CLAIM FOR DAMAGES AND <br /> BENNIE HEIN, INDIVIDUALLY AND INDEMNITY AGAINST <br /> 9 DOING BUSINESS AS NORGE SAN JOAQUIN COUNTY <br /> CLEANERS AND NORGE CLEANING PUBLIC HEALTH SERVICES <br /> 10 VILLAGE, AND BONNIE K. CROSBY, <br /> INDIVIDUALLY AND DOING BUSINESS <br /> 11 AS NORGE CLEANERS AGAINST <br /> SAN JOAQUIN COUNTY PUBLIC <br /> 12 HEALTH SERVICES <br /> 13 <br /> 14 BENNIE HEIN, individually and d/b/a NORGE CLEANERS and NORGE <br /> 15 CLEANING VILLAGE; and BONNIE K. CROSBY, individually and doing <br /> 16 business as NORGE CLEANERS hereby present and make their claim <br /> 17 against the SAN JOAQUIN COUNTY PUBLIC HEALTH SERVICES ("Health <br /> 18 Services") for damages and full and/or partial indemnity arising <br /> 19 out of the discovery in November 1984 and early 1985 of <br /> 20 contaminants in the public sewer system and public drinking water <br /> 21 wells located adjacent to a shopping center commonly known as <br /> 22 Lincoln Center, located at or near the intersection of Pacific <br /> 23 Avenue and Benjamin Holt Drive in the unincorporated area of <br /> 24 San Joaquin County near Stockton, California . Claimants <br /> 25 make the following statements in support of this claim: <br /> 26 1. Claimants' Names : <br /> 27 BENNIE HEIN, individually and d/b/a NORGE CLEANERS <br /> and NORGE CLEANING VILLAGE <br /> 28 <br /> w OFFICES of <br /> 00...UE BONNIE K. CROSBY, individually and d/b/a NORGE CLEANERS <br /> .wo <br /> CwLLAHAW <br /> scmw.s owns 1 <br /> SVI.0 300 <br /> .w t0 C9f O}f <br /> 999.w1..♦ <br />