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r <br /> State Bar No. <br /> 1 Kathy L. Monday,Matthew 0. rS ate Bar No. 209084 8 <br /> 2 DAMREOS,LL,NELSOPACHR&SCSpALLIHRIMP, <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 STATE WATER RESOURCES CONTROL BOARD <br /> s <br /> 9 OF <br /> DECLARATION OF MABEL KEIR IN SUPPORT OF PETITION FOR REVIEW <br /> 10 DECISION OF LOCAL DEPARTMENT <br /> SEAN JO DQ�Q ST FOR ST?IRRONMENTAL HEALTH <br /> 11 <br /> 12 I, Mabel Keir, declare: <br /> 13 1. I am the Petitioner in this matter. <br /> 14 2. My husband,Duncan Keir(now deceased), and I purchased the property <br /> 15 located at 1601 Turnpike, Stockton, California(hereinafter the "Property") from Turnpike <br /> 16 Associates, a partnership, on April 16, 1986. <br /> 17 3. The underground storage tank located on the Property was not used during our <br /> 18 ownership of the Property and was removed on October 14, 1987. <br /> 19 4. We sold the Property to R.L.C. Labor Service, Inc. on August 30, 1993. <br /> 20 5. 1 am aggrieved by the San Joaquin County Environmental Health <br /> 21 Department's (SJCEHD) failure and refusal to name Turnpike Associates and the general <br /> 22 partners of Turnpike Associates as additional responsible parties in that I am being held <br /> 23 responsible for assessing and cleaning up the site at 1601 Turnpike when my actions did not <br /> 24 contribute to the contamination,while the parties who are most likely to have caused the <br /> 25 contamination are not being held responsible. <br /> 26 . . <br /> 27 <br /> 28 <br /> DAMRELL,NELSON <br /> SCHRRAP,PALLIOS <br /> PACHER&SILVA 1 <br /> A Profmiowl <br /> Corporation <br />