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9 m <br /> G <br /> Damrell Nelson Schrimp <br /> Pallios Pacher &Silva <br /> ATTORNEYS <br /> A Professional corporation <br /> 1601 1 Street <br /> Duane L. Nelson <br /> Roger M.Schrimp March 18, 2004Floor <br /> Modesto,CA 95354 <br /> Steven G.Palllos (209)526.3500 <br /> Matthew 0.Pacher Fax:(209)526-3534 <br /> Fred A.Silva www.damrell.com <br /> James F.Lewis <br /> Clinton P.Walker Direct E-mail for: <br /> Michelle Burke McKenzie Kathy L.Monday <br /> John K.Peltier - kmonday@damrell.com <br /> Amy Elliott Neumann <br /> Stephen V.lmburg Victoria L. McCartney <br /> Robert V.Garcia <br /> Kathy L.Monday Environmental Health Department <br /> Maria Fatima Gioletti <br /> Stacy L.Sisco San Joaquin County <br /> Grace Nerona Chan 304 E. Weber Avenue, Third Floor - <br /> Betty L.Julian <br /> George P.Rodarakis Stockton, California 95202-2708 <br /> Chad R.Vanisko <br /> Nicole D.Delerio <br /> Re: Lopez Property <br /> Frank C.Damrell 1601 Turnpike <br /> (1898-1988) <br /> Stockton, California 95206 <br /> Of Counsel <br /> Richard Douglas Brew <br /> Dear Ms. McCartney: <br /> On March 9, 2004, I spoke with Margaret Lagorio of your office and inquired as to <br /> why R. Goold& Son(a corporation which was dissolved in December of 1986)had been <br /> added as a responsible party rather than Turnpike Associates, the partnership which <br /> owned the property prior to the Keirs, and during the time which the tank was being <br /> operated. Ms. Lagorio stated that the partners of Turnpike Associates had told her that <br /> they leased the property to R. Goold & Son and that it was R. Goold & Son that had <br /> operated the tank. She also explained that the same men who formed the Turnpike <br /> Associates partnership were the principals of, or involved with, the R. Goold& Son <br /> corporation. I explained to Ms. Lagorio that the corporation was no longer in existence <br /> and that the general partners of Turnpike Associates should be named as responsible <br /> parties since it was the partnership that owned the property during the time the tank was <br /> in operation. Accordingly, I requested that the general partners of Turnpike Associates be <br /> named as responsible parties. I explained that it's not fair to name a parry that likely had <br /> not contributed to the contamination and omit the party who most likely caused the <br /> contamination. Ms. Lagorio abruptly responded stating, "life is not fair." After much <br /> discussion, Ms. Lagorio ultimately refused to name Turnpike Associates as a responsible <br /> party and suggested that I file a petition with the State Water Board because"they're the <br /> ones with the lawyers." <br /> Accordingly, Mrs. Keir is filing a petition with the State Water Resources Control <br /> Board. To that end,pursuant to State Water Resources Control Board Resolution No. 88- <br /> 23, Local Oversight Program Guidebook Section 11 (2)(B)(8), we request that your <br /> agency provide us with a list of persons known by the San Joaquin County <br /> E XH I BIT <br /> D <br />