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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~xNis~T ~ ~1 ~-~. Anthony P.Ambrosio Attorney at Law 317 Belleville Avenge Bloamfeeld, New Jersey~07003 E-1V~ail: apambroaionavahoo.~om~ Telephone 973-748-7474 a"--~ 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

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