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MICHAEL V BRADY <br />vl.CDONOUGH, HOLLAND & ALLEN <br />A PROFESSIONAL CORPORATION <br />ATTORNEYS <br />555 CAPITOL MALL, 9TH FLOOR <br />SACRAMENTO, CALIFORNIA 95814 <br />(916) 444 -3900 <br />TELECOPIER: (916) 444-8334 <br />TUBA CITY OFFICE <br />422 CENTURY PARK DRIVE, SUITE A <br />P0 BOA 776 <br />TUBA CITY. CALIFORNIA 95992-0776 <br />(916) 674-9761 <br />TELECOPIER (916) 671-0990 <br />BAY AREA OFFICE <br />1999 HARRISON STREET, SUITE 1300 <br />OAKLAND. CALIFORNIA 94612 <br />(510) 444-7372 <br />TELECOPIER (510) 839-9104 <br />July 1, 1994 <br />Ms. Caroline Nascimento <br />San Joaquin County Public Health Services <br />P.O. Box 0388 <br />Stockton, California 95201 <br />RE: Complaint: California Cedar Products Company <br />Dear Caroline, <br />This is intended to follow up on our conversation last week regarding <br />the above referenced property. I am an attorney for Marlowe Properties <br />("Marlowe"). Marlowe owns property at 4630 - 4698 East Waterloo Road in <br />Stockton, California. Marlowe is filing this complaint in the belief that its <br />neighbor, California Cedar Products Company ("Cal Cedar") and its tenant, <br />L. O'Reilly and Son, Inc. ("O'Reilly") are the sources of the solvent <br />contamination beneath the Marlowe property and surrounding properties. <br />I. Facts. <br />Marlowe has been remediating the affects of a leaking underground <br />storage tank on its property the last few years. In connection with that <br />remediation it discovered chlorinated hydrocarbon contamination in the <br />groundwater beneath the site. Subsequent sampling from surrounding <br />properties showed that they too were contaminated with chlorinated <br />hydrocarbons, specifically, methylene chloride, TCE and DCE, as well as <br />others. <br />The County has directed Marlowe to take various steps to further <br />investigate the contamination, such as paying for additional wells and <br />samples. A copy of the County's chronology is attached for your review. In <br />January of this year one of Marlowe's tenants filed a personal injury suit