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09/17/97 WED 13:57 FAX 209 468 0314 SJDA 4 FLOOR zoo3 <br /> JOHN 0 0 <br /> Office of the District Attorney <br /> PHILI" San Joaquin County Courthouse,Rm.202 <br /> DISTRICT ATTORNEY 222 E Weber Ave.Stockton.California 9520: <br /> San Joaquin County P.0-13ox 990,Stockton,California 95201 <br /> Telephone:(209)468-2400 <br /> July 10, 1997 <br /> Mr. Jim Struck <br /> Struck Law Finn <br /> 1411 "G" Street <br /> Modesto,CA 95354 VIA FACSIMILE 574- 1 4 AND FIRST CLASS MAIL <br /> People v.James Ramsey,Frank Guinta,et al.; S.J.Co. Sup. Ct.No.271126 <br /> Dear Mr. Struck: <br /> Thank You and Your client again for meeting with our off ice and PHS-E <br /> HD staff yesterday,in <br /> what we feel was a very productive and cooperative meeting. As discussed in this meeting,the <br /> work plan for corrective action on the site is due as soon as possible but no later than August 1, <br /> 1997. The plans for your client's tank removal/tank system replacement is also due no later than <br /> August 1, 1997, <br /> Further,as we discussed at the conclusion of the meeting,we have asked You to stipulate that <br /> your client will not object to being later added as a "Doe" defendant to any supplemental <br /> complaint that may become necessary to file against Mr.Ramsey covering the period after the <br /> first amended complaint filing,May 5, 1994. If you agree to stipulate,please confirm in writing, <br /> so that we do not have to name your client in any new complaint should such become necessary. <br /> Thanks again for your assistance In this matter. <br /> Sincerely, <br /> OFFICE OFT DISTRICT ATTORNEY <br /> DIANE P. KILCOYNE <br /> Deputy District Attorney <br /> Environmental Prosecutions unit <br />