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Mr. Andrew Smith <br /> Herman&Helen's Marina <br /> July 17,2000 <br /> Page 2 <br /> 2. I have addressed the, "no admission of liability" issue. Is this adequate for Herman & <br /> Helen's? <br /> 3. I have outlined my concern regarding adequate insurance and I have given you the <br /> name and phone number of someone for Condor to call or for you to call for umbrella <br /> insurance. I need a reasonable response that will respond to our concern. Mr. Jeffrey <br /> Case is just one avenue. You may also consider Golden Bear Insurance in Stockton. <br /> These are merely local companies with whom I have general familiarity. I am not <br /> suggesting that Herman& Helen's only consider these companies; there may be many <br /> others who have the means to address your insurance needs. However, it does not <br /> appear that Herman & Helen's has taken any action to address our concerns on this <br /> matter. Because you are desire to investigate a plume potentially underlying my <br /> client's property that may be emanating from the Manna, we suggest that you need to <br /> do some leg work to address this matter. The Bank will provide reasonable access to <br /> the property so long as Herman & Helen's Manna provides standard reasonable <br /> assurances(protections)prior to entering the property. <br /> 4. I have outlined our concern and request for a tolling of the statute of limitations. <br /> Herman and Helen's has not responded. Where do we stand on this issue? <br /> If you should have any questions, do not hesitate to call. <br /> Very truly yours, ,/ <br /> V ka1 <br /> BROOKE BIRKIE VOS <br /> Attorney at Law <br /> Enclosure <br /> cc: Walt Wolterstorff (w/o encl.) <br /> J<on Rowe-SJCPHS/EHD (w/o encl.) <br />