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Neumiller & Beardslee A PROFESSIONAL CORPORATION FOUNDED AS MAILING ADDRESS A EUMILLER ATTORNEYS AND COTJNSELORS P. O. BOX to JANUARY 1903 STOCKTON, CALIFORNIA 952at-3020 FIFTH FLOOR WATERFRONT OFFICE TOWER II TELEPHONE IZO91949--BZOQ so9 WEST WEBER AVENUE FAX (ZO9) 94e-4910 STOCKTON , CALIFORNIA 9SE03 31050 - 19257 January 2. 6 , 1993 ?, � € (3 is JAN 2 81999 Mr . Michael Infurna San Joaquin County Public Health Services / Environmental Health Division 445 North San Joaquin Stockton , CA 95202 Re ; 4405 Pacific Avenue , Stockton , CA Our File 31050 - 19257 Dear Mr . Infurna : This letter follows up on our telephone conversation of January 25 , 1993 . As you know , Mr . Pete Giambanco has unexpect- edly passed away . The Estate is presently being formed , and we have been informed that our _law firm will be retained in ad - dressing matters associated with the above - referenced proper- ty . The Estate , once formed , is legally a distinct person separate from Mr . Peter Giambanco . Thus , the Estate will be making its own decisions as to what should be done regarding the above - referenced property . For purposes of legal notifica - tion , you should address correspondence to : Michael Gianelli , Esquire Gianelli Brew 1014 16th Street Box 3212 Modesto , CA 95353 As a new and separate individual , the Estate which is being formed has the option to proceed with current litiga - tion . As you may recall , Shaunessy had sued Giambanco for judicial foreclosure and Giambanco counter- claimed for rescis - sion . Once formed , one of the first things the Estate will decide is whether to proceed with or abandon the rescission claim . If the Estate decides to pursue and does prevail on a rescission suit , the result would mean that Giambanco never owned the property . Thus , the potential result is significant when determining who is the appropriate responsible party .