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4r � <br /> G. S. Garrison, Esq. <br /> November 25, 1992 <br /> Page 2 <br /> will bring all of their own records to the meeting, so that we <br /> should essentially have the entire record there. However, we <br /> certainly would not have the time or ability to make an evaluation <br /> as to what is provided during the course of your suggested meeting. <br /> We need to have the entire record in advance, and have it reviewed <br /> by our own advisors, before we could intelligently discuss the <br /> matter of allocating responsibility. <br /> Also, our respective clients are not the only allegedly responsible <br /> parties. I am advised that my clients had owned the subject <br /> property for only somewhat less than six years, when they sold the <br /> property to your clients. I am also advised that my clients <br /> acquired the property from Harry Gebauer and Donald Allen, who had <br /> been using the property (with the underground tank or tanks) for <br /> at least five years and most likely for substantially longer than <br /> that, when they sold the property to my clients. Messrs. Gebauer <br /> and Allen had been leasing the property from R. L. Walters and <br /> Florence Walters until shortly before they sold the same to my <br /> clients. Apparently, they purchased the property from Mr. and Mrs. <br /> Walters under an option in the lease, and then immediately resold <br /> the property to my clients. <br /> Also, the situation here concerning who might be responsible <br /> parties needs a considerable amount of additional clarification. <br /> Obviously, it will be necessary to determine when the underground <br /> tank or tanks were installed, and the actual period of time during <br /> which Messrs. Gebauer and Allen used those tanks as lessees at the <br /> property. By the way, the business in which they used the tank or <br /> tanks at the property was called Cal State Trucking Co. Also, I <br /> have been told that Mr. Walters is deceased, although Mrs. Walters <br /> may still be living. There may be others who owned or leased the <br /> property while the tank or tanks were in place there, whom we have <br /> not as yet identified. <br /> Therefore, before any meeting (such as the one you suggest) is <br /> held, we need to clarify the situation with respect to who may or <br /> may not be responsible parties here, and arrangements need to be <br /> made so that all of those who may be responsible parties attend. <br /> In other words, my clients are not willing to enter into any <br /> negotiations that involved only them and your clients. This is <br /> especially the case considering that my clients operated a business <br /> at the property apparently only for a very small portion of the <br /> overall period of time when the underground tank or tanks were in <br /> Place and may have been leaking. <br /> For these reasons, my clients will not be attending the meeting you <br /> are calling for December 4, 1992. On the other hand, if you will <br /> provide us with copies of the entire record as indicated above, and <br /> if you will work with us in obtaining all of the other information <br /> that we require as also indicated above, we will be pleased to <br />