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N Fi } <br /> I <br /> Damrell Nelson Schfimp <br /> Paws Parher Epp Silva <br /> ATTORNEYS <br /> A Professional Corporation <br /> Duane L. Nelson Janll 1601 1 Street <br /> Roger M. Schrimp �26 e 20 04 <br /> Fifth Floor <br /> Steven G.Pallios Modesto, CA 95354 <br /> Matthew 0.Pacher (209) 526-3500 <br /> Fred A. Silva Fax: (209) 526-3534 <br /> James F. Lewis www.damrell.com <br /> Clinton P. Walker <br /> Michelle Burke McKenzie Direct E-mail for: <br /> James M. Lindsay Kathy L. Monday <br /> Thomas P.Hogan Via facsimile (209) 464-0138 kmonday@damrell.com <br /> John K. Peltier <br /> Amy Elliott Neumann and U.S. Mail <br /> Stephen V.Imburg <br /> Robert V. Garcia <br /> Kathy L. Monday Victoria L. McCartney <br /> Gene J. arger <br /> Maria Fatima Lima GiGioletti Environmental Health Department <br /> Stacy L. Sisco San Joaquin County <br /> Grace NeronaChan <br /> Betty L..Julian 304 E. Weber Avenue Third Floor <br /> Julia <br /> George P. Rodarakis Stockton, California 95202-2708 <br /> Chad R.Vanisko <br /> Frank C. Damrell Re: Lopez Property <br /> (1696-1986) 1601 Turnpike <br /> Of Counsel Stockton, California 95206 <br /> Richard Douglas Brew <br /> Dear Ms. McCartney: <br /> After reviewing our client Mrs. Keir's documents, and gathering information <br /> regarding the history of the site and the underground storage tank(UST), it appears that <br /> Mrs. Keir has been incorrectly named as the"primary"responsible party. <br /> The Keirs purchased the subject property in April of 1987. At the time of <br /> purchase, the UST located on the property was empty. On January 21, 2003, I confirmed <br /> this fact with one of the previous owners who sold the property to the Keirs,Bill Snyder <br /> of Turnpike Associates.' As confirmed by Mrs. Keir,the Keirs never used or operated <br /> the UST. Rather, they had it removed with all the appropriate permitting in October of <br /> 1987. The UST was intact when removed as confirmed by the County's records. Thus, <br /> the removal of the UST did not cause the unauthorized release of a hazardous substance. <br /> Under these circumstances, it is obvious that if any unauthorized release occurred at the <br /> property, it occurred prior to the time the Keirs became owners. Accordingly, the <br /> previous owners and/or operators should be named as the"primary"responsible parties <br /> and Mrs. Keir as a secondary party, if at all. <br /> 1 Notably,during the San Joaquin County Environmental Health Department's previous <br /> involvement regarding the site in the 1990's,Bill Snyder of Turnpike Associates was <br /> named as a responsible party.. Thus,we assume your agency must have the relevant <br /> information regarding Mr. Snyder's ownership of the property and/or operation of the <br /> UST. <br /> EXHIBIT <br />