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cri <br /> 2 <br /> �1100 <br /> 3 1. The claimant is Delta Funding, L.P., a California limited partners sir he <br /> � 4 <br /> 4 claimant's mailing address is 5361 N. Pershing, Suite B, Stockton, California 95207. F om on <br /> 5 or about May 1, 1997 until on or about February 18, 1998, when the Lynch Property reverted <br /> 6 to Delta Funding as the result of foreclosure and trustee's sale, Delta Funding, in its capacity <br /> 7 as a lender, maintained a security interest in the Lynch Property for the purpose of securing its <br /> 8 loan to Leonard Lynch. Delta Funding has never operated a solid waste disposal facility on <br /> 9 the Lynch Property, or permitted or authorized anyone else to operate such a facility or <br /> 10 otherwise disposed of waste of any kind on the property. <br /> 11 2. Delta Funding is informed and believes that prior to 1988, the Lynch Property <br /> 12 was part of what was known as the Snyder Dump, which was later subdivided into two <br /> 13 parcels, one of which became the Lynch property. Delta Funding is also informed and <br /> 14 believes that in or about 1989, San Joaquin County authorities took enforcement action against <br /> 15 the owner of the Lynch Property and removed solid waste that had been disposed of at the <br /> 16 Lynch Property. <br /> 3. Delta Funding is further informed and believes that commencing in or about <br /> 17 <br /> April 1997, San Joaquin County took additional action to abate conditions on the Lynch <br /> 18 <br /> Property, including demolishing substandard structures and removing solid waste and debris <br /> 19 <br /> from the property. <br /> 20 <br /> 4. On or about May 1, 1997, unaware that San Joaquin County had taken <br /> 21 <br /> abatement and enforcement action against the Lynch Property,Delta Funding, recorded a first <br /> 22 <br /> trust deed on the property in the amount of$30,000. At the time of Delta Funding's loan to <br /> 23 <br /> Leonard Lynch, the appraised value of the Lynch Property was approximately $110,000. Mr. <br /> 24 <br /> Lynch defaulted on,the loan, and on October 14, 1997, Delta Funding recorded a Notice of <br /> 2s <br /> Default against the Lynch Property. On February 18, 1998,a foreclosure sale was conducted <br /> 26 and the Lynch Property reverted to Delta Funding. <br /> 27 <br /> 5. Admitting that Delta Funding was as a bona fide purchaser without notice, San <br /> 28 Joaquin County, on or about May 27, 1998, released the Notice of Abatement Action that it <br /> 2 <br /> CLAIM FOR DAMAGES <br />