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1 Matthew 0. Pacher, State Bar No. 109378 <br /> Kathy L.Monday, State Bar No. 209084 <br /> 2 DAMRELL,NELSON, SCHRROP, <br /> PALLIOS,PACHER& SILVA <br /> 3 16011 Street, Fifth Floor <br /> Modesto, CA 95354 <br /> 4 Telephone: (209) 526-3500 <br /> Facsimile: (209) 526-3534 <br /> 5 <br /> Attorneys for Petitioner <br /> 6 <br /> 7 <br /> 8 STATE WATER RESOURCES CONTROL BOARD <br /> 9 <br /> 10 PETITION FOR STAY OF LOCAL AGENCY ACTION, SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DEPARTMENT <br /> 11 <br /> 12 1. Petitioner Mabel Keir is a previous owner of property located at 1601 Turnpike, <br /> 13 Stockton, California(hereinafter the"Property"). The Property has been assigned to the San <br /> 14 Joaquin County Environmental Health Department's Local Oversight Program for oversight of <br /> 15 assessment and clean up activities at contaminated underground storage tank sites (Site Code <br /> 16 0001525). Petitioner has been named as a primary responsible party with regard to the <br /> 17 investigation and clean up of the site. Petitioner has been ordered to submit a workplan to the <br /> 18 San Joaquin County Environmental Health Department to investigate the lateral and vertical <br /> 19 extent of contamination at the site by April 5, 2004. <br /> 20 2. Petitioner has simultaneously filed a Petition with the State Water Resources <br /> 21 Control Board (SWRCB)to review the inaction by the San Joaquin County Environmental <br /> 22 Health Department's Local Oversight Program in failing and refusing to name Turnpike <br /> 23 Associates, a partnership, and the partners thereof, Bill Snyder, Mervyn Totman, and Ralph <br /> 24 Smith, as responsible parties with regard to the site. <br /> 25 3. Petitioners hereby request a stay of the San Joaquin County Environmental Health <br /> 26 Department's action in ordering her to submit a workplan until the State Board acts on <br /> 27 Petitioner's Petition for Review. <br /> 28 . . <br /> DAMRELL,NELSON <br /> SCHRIMP,PALLIOS <br /> PACHER&SILVA <br /> A Professional <br /> Colporerion <br />