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r <br />0 lU 0 1 1 1 c E s <br />O T T 0 P, 0 E 9 f <br />6A Professional Corporation <br />AV -Preeminent Rated <br />Re: Your Client: Anna Nahlil< <br />Real Property Partition (APN 009 — 190-26) <br />Dear Mr. Vignolo: <br />Please be advised that Ms. Tower does not accept your client's demand of $400,000.00 for <br />the buyout. The undersigned was informed that the purchase price was based on offers that our clients <br />jointly made for properties located in Chowchilla, California and Gustine, California. These offers are <br />entirely irrelevant and do not qualify as proper comparables for the issue at hand. <br />Ms. Tower is willing to raise her offer to $5,000.00 per acre. This results in a net purchase <br />price of $132,100.00 based on offsets for the promissory note owed by Ms. Nahlik to Ms. Tower <br />($60,000.00), the attorney fees for the Coyote Creek Ranch, LLC Operating Agreement ($900.00) and <br />the overcharges for the test well ($7,000.00). This offer will remain open until February 21, 2017, at <br />5:00 p.rn. <br />In addition, this office previously forwarded a letter from the County of San .Joaquin regarding <br />the test well. The undersigned has been informed that it will be necessary for Ms. Nahlik to cancel the <br />existing well permit. Please contact the undersigned regarding this issue at your earliest convenience. <br />Thank you. <br />Very truly yours, <br />LAW OFFICES OF BRUNN & FLYNN <br />A Professional or tion <br />,MAHANVIR S. SAHOTA <br />MSS/cds <br />K:\docs\cases\6369-16335\vignolo 2-10-17 <br />Charles K. Brunn <br />Timothy T. Flynn <br />February 13, 2017 <br />Gerald E. Brunn <br />Michael G. Donovan <br />Mahanvir S. Sahota <br />BY E-MAIL AND U.S. MAIL <br />John K. Peltier <br />Geoffrey W. Hench <br />avignolo(a)downeybrand.com <br />928 12th Street, Suite 200 <br />Modesto, CA 95354 <br />Anthony Vignolo <br />Phone: (209) 521-2133 <br />DBrand <br />Downey <br />Fax: (209) 521-7584 <br />www.brunnandflynniaw.com <br />3425 Brookside Road I Suite A <br />Stockton, CA 95219 <br />e-mail: MSahota@brunn-flynn.com <br />Re: Your Client: Anna Nahlil< <br />Real Property Partition (APN 009 — 190-26) <br />Dear Mr. Vignolo: <br />Please be advised that Ms. Tower does not accept your client's demand of $400,000.00 for <br />the buyout. The undersigned was informed that the purchase price was based on offers that our clients <br />jointly made for properties located in Chowchilla, California and Gustine, California. These offers are <br />entirely irrelevant and do not qualify as proper comparables for the issue at hand. <br />Ms. Tower is willing to raise her offer to $5,000.00 per acre. This results in a net purchase <br />price of $132,100.00 based on offsets for the promissory note owed by Ms. Nahlik to Ms. Tower <br />($60,000.00), the attorney fees for the Coyote Creek Ranch, LLC Operating Agreement ($900.00) and <br />the overcharges for the test well ($7,000.00). This offer will remain open until February 21, 2017, at <br />5:00 p.rn. <br />In addition, this office previously forwarded a letter from the County of San .Joaquin regarding <br />the test well. The undersigned has been informed that it will be necessary for Ms. Nahlik to cancel the <br />existing well permit. Please contact the undersigned regarding this issue at your earliest convenience. <br />Thank you. <br />Very truly yours, <br />LAW OFFICES OF BRUNN & FLYNN <br />A Professional or tion <br />,MAHANVIR S. SAHOTA <br />MSS/cds <br />K:\docs\cases\6369-16335\vignolo 2-10-17 <br />