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k <br /> PW <br /> BORGMANN, HANLON, SCHWARTZ & WILSON;=LLC ,, f .y <br /> 1 =4. - fir; , J <br /> ATTORNEYS AT LAWL. 'i <br /> t01 SOUTH HANLEYf 4 11 <br /> r+I r: of- ��• <br /> SUITE 1280 h <br /> A", INTERCO CORPORATE TOWER <br /> . � w. z. 1- 14 7- 1 <br /> CLAYTON,MISSOURI 63105 t <br /> April�7, 1998 <br /> TELEPHONE 725.5955 '_ t'x .S4 t;=, r � <br /> FACSIMILE-725.0559 <br /> Mr. Jerry Gregerson <br /> Gregerson& Associates, Inc. <br /> 878 W. Benjamin Holt Dr. <br /> Stockton, CA 95207 <br /> Re: 1717S. Center en er S t. <br /> Stockton, CA <br /> Dear Mr. Gregerson:; E <br /> I <br /> I am in receipt of your correspondence dated March 5; 1998, received March 20, 1998, <br /> regarding the environmental issue at above referenced property. Your analogies and references <br /> to unconventional business practices are quite unclear and somewhat confusing. As stated in my <br /> previous correspondence, Earthgrains has attempted to work with you, at your request,to resolve <br /> this matter. Earthgrains has moved forward towards the performance of additional site <br /> characterization work with the belief and expectation.that you would share in the responsibility <br /> for such,work. As I stated in previous correspondence to you, Earthgrains is not contractually <br /> obligated to you to perform any of this additionalx;environmental work at the property and has <br /> continued to cooperate with San Joaquin County.Public Health Services on.a voluntary basis. I <br /> have reviewed the files regarding this matter and I suggest that you review the Release ` <br /> Agreement that you executed in 1994. You`should also consider the fact that you may be i <br /> eligible for recovery"from the California Underground Storage Tank Fund. <br /> Upon completion of the current environmental work being performed by Earthgrains at <br /> the property, Earthgrains will look to you for full reimbursement of its costs, including <br /> reasonable attorney's fees, relating to this matter. <br /> _-I-encourage you or your`legal`counsel'to`contact me as sooir-a:s-possible>to-discuss a- <br /> resolution of this matter. <br /> Very truly yours, <br /> Borgmann,Hanlon, Schwartz &Wilson, L.L.C. <br /> By <br /> John W. Traeger <br /> JWT/lrr i <br /> cc: igr..Michael.J..-Infuma, Jr. —PHS-EHD E <br /> Ms. Theresa�Lanctot—The Earthgrains Company <br /> I <br />