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L <br />L-1 <br />BRAY, GEIGER, RUDQUIST & NUSS <br />ATTORNEYS AT LAW <br />DENNIS DONALD GEIGER,. <br />JOHN 0. RUDQUIST <br />JAMES T. C. NUSS <br />ANTHONY S. GUERRIERI) <br />ALAN R. COON <br />STEVEN P. EMRICK <br />PETER A. VIRI <br />LAUREEN J. KEEN <br />Via Facsimile (209) 464-0138 <br />Mr. Steve Mindt <br />County of San Joaquin <br />304 East Weber Avenue, 31 Floor <br />Stockton, California 95202 <br />Dear Mr. Mindt: <br />400 BANK OF STOCKTON BUILDING <br />311 EAST MAIN STREET <br />STOCKTON, CALIFORNIA 95202-2904 <br />TELEPHONE (209) 948-0434 <br />FACSIMILE (209) 948-9451 <br />E-MAIL BGRN@INREACH.COM <br />June 17, 1998 <br />FOUNDED 1882 <br />MARK S. BRAY, OF COUNSEL <br />FRANK D. NICOL (1859-1910) <br />MELVIN H. ORR (1851-1916) <br />W.B. NUTTER (1859.1939) <br />NEWTON RUTHERFORD (1881-1956) <br />D. R. JACOBS (1892-1970) <br />STEPHEN. DIETRICH (1908-1971) <br />PHILIP CAVALERO (1907-1992) <br />This office represents Cal State Mortgage Co., Inc., the owner by foreclosure on that property in <br />Riverbank, commonly known as 23023 Santa Fe Road, Riverbank, California. It has come to my attention <br />that the County is attempting, yet again, to file an action for cleanup on the property. It is quite apparent that <br />the County targeted this property when it learned that the lien previously filed against the County proved <br />unenforceable as to Cal State. I am also informed that the County's selected clean up crew purposely left <br />some of the tires on the property so that there would be no easy access to the property. In other words, the <br />County's agents purposely left the very same problem which they are now attempting to claim was not <br />cleaned up by Cal State Mortgage, which only recently acquired the property through foreclosure. <br />Furthermore, I am informed and believe that a Notice of Substandard Building is still recorded on <br />the property. <br />In addition, we are informed that certain County officials have been making derogatory comments <br />and statements regarding saleability of the property to prospective brokers and buyers. Such contact <br />interferes with the contras ual rights that Cal State has with these parties. In short, the County is interfering <br />with potential contracts of sale. <br />Therefore, I must ask that you cease and desist, release the Notice of Substandard Building and <br />refrain from further targeting of this property. You may confirm your response by directing a letter to the <br />undersigned by no later than Friday, June 19, 1998. My fax number is (209) 948-9451. <br />Sincerely yours, <br />BRAY, GEIGER, RUDQUIST & NUSS <br />ell, I <br />By <br />Alan chard Coon <br />ARC:lh <br />cc: Cal State Mortgage Co., Inc. <br />