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FDPVSTV9 <br />sTTORNEY <br />San Joaquin County <br />June 11, 1997 <br />tuo V0114 _ J 1Ui i rLVVK It003 <br />t� <br />Of bof the District Attorney <br />San Joaquin County Courthouse, RM- 202 <br />222 E Weber Ave. Stockton, California 95202 <br />P.O.Box 990, Stockton, California 95201 <br />Telephone:(209) 468-2400 <br />Mr. Peter Manion <br />Hakeem, Ellis & Simonelli <br />2800 West March Lane, Suite 200 <br />Stockton, CA 95219 VIA FACSIMILE 474-3654 AND FIRST CLASS MAIL <br />RE: PEOPLE v. RALPH LEE WHITE et al., Sup. Ct. # 282387 <br />Dear Mr. Manion: <br />This letter is to update you on the meeting held at our office, with Mr. White and his attorney <br />Mike Babitzke on June 9, 1997. At this meeting, it was agreed that they would have signed a <br />contract by July 15, 1997, with a licensed contractor to remove the tanks at Ralph's Square. It <br />was further agreed that the permit application to remove the tanks would be submitted to <br />Environmental Health for approval before August 1, 1997, and that the tanks would be properly <br />removed before November 1, 1997. 1 am sure that you and your client will make every possible <br />effort in good faith to work with Mr. White and his attorney in order to make this settlement <br />agreement work. Mr. Babitzke should be contacting you shortly to discuss such; if he does not, I <br />would ask that you contact him. <br />We also agreed that all discovery deadlines and filing deadlines for motions to compel would be <br />stayed until at least August 1, 1997, thereby preserving the respective rights and responsibilities <br />of all parties under the discovery rules_ If you do not agree, please contact me immediately at <br />468-2309. Thank you for your assistance in this matter. <br />Sincerely, <br />OFFICE OF THE DISTRICT ATTORNEY <br />DIANE P. KiLCOYNE� <br />Deputy District Attorney <br />Environmental Prosecutions Unit <br />