Laserfiche WebLink
1 4. Petitioner's request for a stay is warranted because unless a stay is granted, <br /> 2 Petitioner will have to unilaterally pay for and submit a workplan that Petitioner, in good faith, <br /> 3 believes should be the responsibility, or shared responsibility of several unnamed responsible <br /> 4 parties. <br /> 5 5. No substantial harm to other interested persons or the public will occur if the stay <br /> 6 is granted in that the stay is requested only with regard to the submission of the workplan and <br /> 7 only until the State Board acts on Petitioner's Petition for Review. <br /> 8 6. Substantial questions of fact and law exist regarding the San Joaquin County <br /> 9 Environmental Health Department's Local Oversight Program in failing and refusing to name <br /> 10 Turnpike Associates, a partnership, and the partners thereof,Bill Snyder,Mervyn Totman, and <br /> 11 Ralph Smith, as responsible parties with regard to the site. (See, Petitioner's Petition and <br /> 12 supporting declarations submitted herewith.) <br /> 13 <br /> 14 Dated: March 25, 2004 DAMRELL,NELSON, SCHRIMP, <br /> PALLIOS, PACHER & SILVA <br /> 15 <br /> 16 Kathy L. Mo y <br /> 17 Attorneys for etitioners <br /> G:\MATTT,EIR\S W RCBPleadings\STAY.wpd <br /> 18 <br /> 19 <br /> 20 <br /> 21 <br /> 22 <br /> 23 <br /> 24 <br /> 25 <br /> 26 <br /> 27 <br /> 28 <br /> DAMRELL,NELSON <br /> SCEQIIMP,PALLIOS <br /> PACHER&SILVA <br /> A Professional 2 <br /> Coryoatlon - <br />