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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 />By: <br />ALBERT M. ELLIS <br />AME/rjs <br />cc: George Badway <br />