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Damrell Nelson Schrimp Pallios Paeher &Silva ATTORNEYS A Professional corporation Duane L.Nelson 1601 1 Street Roger M.Schdmp March 18, 2004 Fifth Floor Steven G.Palllos Modesto,CA 95354 Matthew O.Pacher (209)526-3500 Fred A.Silva Fax:(209)526-3534 James F.Lewis www.damrell.com Clinton P.Walker Michelle Burke McKenzie Direct E-mail for. John K.Peltier Kathy L.Monday Amy Elliott Neumann kmondayCdamreil.com Stephen V.Imburg Victoria L. McCartney Robert V.Garcia Kathy L.Monday Environmental Health Department Maria Fatima Gioletti San Joaquin County Stacy L.Sisco q Grace Nerona Chan 304 E. Weber Avenue, Third Floor Betty L.Julian George P.Rodarakis Stockton, California 95202-2708 Chad R.Vanisko Nicole D.Delerio Re: Lopez Property Frank C.Damrell (1898-1988) 1601 Turnpike Of Counsel Stockton, California 95206 Richard Douglas Brew Dear Ms. McCartney: On March 9, 2004,I spoke with Margaret Lagorio of your office and inquired as to why R. Goold &Son(a corporation which was dissolved in December of 1986)had been added as a responsible party rather than Turnpike Associates, the partnership which owned the property prior to the Keirs, and during the time which the tank was being operated. Ms. Lagorio stated that the partners of Turnpike Associates had told her that they leased the property to R. Goold& Son and that it was R. Goold& Son that had operated the tank. She also explained that the same men who formed the Turnpike Associates partnership were the principals of, or involved with, the R. Goold& Son corporation. I explained to Ms. Lagorio that the corporation was no longer in existence and that the general partners of Turnpike Associates should be named as responsible parties since it was the partnership that owned the property during the time the tank was in operation. Accordingly, I requested that the general partners of Turnpike Associates be named as responsible parties. I explained that it's not fair to name a party that likely had not contributed to the contamination and omit the party who most likely caused the contamination. Ms.Lagorio abruptly responded stating, "life is not fair." After much discussion, Ms. Lagorio ultimately refused to name Turnpike Associates as a responsible party and suggested that I file a petition with the State Water Board because"they're the ones with the lawyers." Accordingly,Mrs. Keir is filing a petition with the State Water Resources Control Board. To that end,pursuant to State Water Resources Control Board Resolution No. 88- 23, Local Oversight Program Guidebook, Section 11 (2)(B)(8), we request that your agency provide us'with a list of persons known by the San Joaquin County 34"