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/Mr. Howard L. Seligman <br />Seligman do Willett, Inc. <br />4505 B Precissi Lane. <br />Stockton, California 95207 <br />Mr. Don A. Cose <br />Cose do Associates <br />Post Office Box 326 <br />Tracy, California 95378-0326 <br />Re: Wakefield Court "Covenant" <br />Gentlemen: <br />MICHAEL J. MATTEUCCI <br />OF COUNSEL <br />TELEPHONE <br />12091 942-4300 <br />� O <br />0--T 2 ;,, 1987 <br />ENVIRWO.ENTAL HEALTH <br />F ERMIT/SERVICES <br />It appears that this office is again forced to request that Mr. <br />Seligman instruct Mr. Cose to cease direct communication with <br />San Joaquin Local Health District personnel regarding matters <br />for which they have retained counsel. <br />I am informed that numerous phone calls and "visits" amounting <br />to harassment by'Mr. Cose and his office staff have occurred, <br />although that same office was unable to provide me with a proper <br />property description or buyers names for the Covenant to be <br />recorded in this matter. <br />Additionally, I have received a copy of the enclosed <br />correspondence from Doris M. Herr of the Cose office directed <br />to the Health District complaining that "preparation and <br />acquiring approval of this Covenant is taking so much time". <br />For your information, review of my file indicates the following: <br />9/3/87 Meeting at County Planning wherein it is agreed <br />that indemnity documents will be drawn up. <br />9/14/87 Both indemnity and disclosure are suggested in <br />correspondence with Mr. Seligman. <br />9/21/87 Mr. Cose's insurance agent inquires as to the <br />needed certificate of insurance. <br />9/23/87 Meeting at Taylor, Scott & Nichols office re <br />indemnity with representatives of San Joaquin County and <br />the Health District. <br />TAYLOR, SC'OTT_& Nit-HOi.S <br />A PROFESSIONAL LAW CORPORATION <br />SICHARO W. TAYLOR <br />W. STEPHEN SCOTT <br />120 N. HUNTER STREET - SECOND FLOOR <br />KENNETH A. NICHOLS <br />STOCKTON. CA 95202 <br />POST OFFICE BOX 1930 <br />MARK E. TRIBBLE <br />STOCKTON, CALIFORNIA 95201 <br />MICHELE M. LARSON <br />October 23, 1987 <br />/Mr. Howard L. Seligman <br />Seligman do Willett, Inc. <br />4505 B Precissi Lane. <br />Stockton, California 95207 <br />Mr. Don A. Cose <br />Cose do Associates <br />Post Office Box 326 <br />Tracy, California 95378-0326 <br />Re: Wakefield Court "Covenant" <br />Gentlemen: <br />MICHAEL J. MATTEUCCI <br />OF COUNSEL <br />TELEPHONE <br />12091 942-4300 <br />� O <br />0--T 2 ;,, 1987 <br />ENVIRWO.ENTAL HEALTH <br />F ERMIT/SERVICES <br />It appears that this office is again forced to request that Mr. <br />Seligman instruct Mr. Cose to cease direct communication with <br />San Joaquin Local Health District personnel regarding matters <br />for which they have retained counsel. <br />I am informed that numerous phone calls and "visits" amounting <br />to harassment by'Mr. Cose and his office staff have occurred, <br />although that same office was unable to provide me with a proper <br />property description or buyers names for the Covenant to be <br />recorded in this matter. <br />Additionally, I have received a copy of the enclosed <br />correspondence from Doris M. Herr of the Cose office directed <br />to the Health District complaining that "preparation and <br />acquiring approval of this Covenant is taking so much time". <br />For your information, review of my file indicates the following: <br />9/3/87 Meeting at County Planning wherein it is agreed <br />that indemnity documents will be drawn up. <br />9/14/87 Both indemnity and disclosure are suggested in <br />correspondence with Mr. Seligman. <br />9/21/87 Mr. Cose's insurance agent inquires as to the <br />needed certificate of insurance. <br />9/23/87 Meeting at Taylor, Scott & Nichols office re <br />indemnity with representatives of San Joaquin County and <br />the Health District. <br />