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David J. Irey <br /> January 6, 2000 <br /> Page 2 <br /> I also found it interesting to learn that in Mr. <br /> Fields memo he further acknowledges that "there is no way <br /> to know how many cylinders were still on site or picked <br /> up. " For all of these reasons, I believe the lawsuit filed <br /> against my client would have significant proof problems <br /> should this matter proceed forward in the litigation <br /> process . I also do not think that my client represents a <br /> risk to the community or for that matter does Mr. Badway <br /> conduct his business in a manner that is in disregard to <br /> the safety of the public or his employees . For all of <br /> these reasons, I would respectfully request that the <br /> lawsuit be dismissed without the necessity of our <br /> responding to the lawsuit, and incurring more fees and <br /> costs for both sides in litigating this action. <br /> I would welcome the opportunity to speak with you <br /> concerning a resolution of this action prior to January 21, <br /> 2000 , at which time you have requested that I have a <br /> responsive pleading on file with the courts . Please <br /> contact me at your earliest convenience so that we might <br /> further discuss this matter. <br /> Very truly yours, <br /> HAKEEM, ELLIS, SIMONELLI & MARENGO <br /> A Professions Corporation <br /> r <br /> By: <br /> ALBERT M. ELLIS <br /> AME/rjs <br /> CC : George Badway <br />