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AW <br /> N <br /> Mr . Michael Infurna <br /> July 2 , 1993 <br /> Page : 2 <br /> you that the Estate may be insolvent . It is possible that the <br /> Court will reject a proposed consultant expenditure because the <br /> pre- existing creditors obligations must be satisfied . The Court <br /> may consider such an expenditure as an attempt to obtain a <br /> higher priority than that of the present set of creditors . <br /> After discussions with the attorneys for the Estate , I <br /> thought it fair to inform you that the Estate may not be <br /> authorized to enter a contract with the consultant of choice for <br /> the workplan and activities proposed and due on July 15 , 1993 . <br /> It is our intent to advise the client of the necessary actions to <br /> remain in compliance with your directives . We will continue in <br /> good faith to achieve that end , but thought you should know of <br /> the limitations of dealing with this Estate as a responsible <br /> party . <br /> Because the prior owner , Shaughnessy , was out of compliance <br /> with tank permits prior to the transfer to decedent Giambanco , <br /> you may want to consider naming the Shaughnessy Estate as an <br /> additional responsible party . It is possible that the <br /> Shaughnessy Estate may have adequate assets to maintain <br /> compliance . <br /> Should you have any questions , do not hesitate to call . <br /> Very truly yours , <br /> BROOKE K . BIRKIE <br /> Attorney at Law <br /> BKB : cm <br /> cc : Michael Gianelli , Esq . <br /> Peter Giambanco , Jr . <br /> F : \TR \19257\C\G111MBAM2 . BKB <br /> 31087/CM/07/02/93/1 <br />