In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation

Filing 3902

DECLARATION of Susan M. Dean in Opposition re: (318 in 1:08-cv-00312-SAS) MOTION for Summary Judgment as to Getty Property Corp.'s Third-Party Complaint.. Document filed by Getty Properties Corp.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13)Filed In Associated Cases: 1:00-cv-01898-SAS-DCF, 1:08-cv-00312-SAS(McMeekin, John)

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Anthony P.Ambrosio
Attorney at Law
317 Belleville Avenge
Bloamfeeld, New Jersey~07003
E-1V~ail: apambroaionavahoo.~om~
Telephone [phone]

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Facsimile 973-7480765

ranuary 22,2007

VYA LAWXERS SERVICE
Stuart J. Lieberman, Esq.
10 Jefferson Plaza
Suite 100
Princeton, New Jersey 48540
Re:

Rob's Towing Service/Robert Melecci
439 Lace Avenue, Colonic, New 7ersev

Dear Stuart:
~'lais letter is to advise you that on Wednesday, January 17,
2007 my client, Robert Meleeci, the owner ofRob's Towing Service
observed a de3ivety being made some time in the afternoon by your clien#'s
gasoline transportation delivery service. During the delivefy gasoline spilled
on the ground and pooled underneath the trunk. Although the spill was
cleaned up, clearly some ofthe gasoline seeped into the group. This spill
appears to be a recurrence of prior spills which inay be the cause ofthe
contamination now being investigated ~y the New Jersey Department of
Environmental Protection ("NJD$P").
Cleazly the method used to deliver the gasoline does not
comply with the standard required for such deliveries. No gasoline should
leak during the delivery and your by your client and the delivery company

Stuart J. Lieberman,Esq,
January 22,2007
Page 2
shall beheld responsible for any adverse consequences for the negligent

manner in which the gasoline deliveries have been made,
Sincerely,
tho

APA/la
cc: Robert W.MuiZenburg,Esq.(via facsimile)
Jay Ricigliano, Esq.(via facsimile)
Mr. Robert Melecci {via facsimile)

P. Ambrosio