Laserfiche WebLink
MULLEN, SULIJV.AN & NEWTON <br /> xip^ HE ! <br /> THOMAS J.NEWTON gTTORN EYS AT LAW "'�•�# € 't . 'Itw. �Jlti � i 6`YCOUNSEL <br /> CRAIG RASM USSEN �s r 1 K(� ROBERT H. MVLLEN <br /> STEPHEN C.SNIDER �ja-� 3 I S�E •C. M.-BUD-SULLIVAN <br /> 1111 WEST TOKAY STREET <br /> JAMES V.DEMERA 111 <br /> P.-O. BOX SAO 'ct} 3CT 13, M-3. 58 <br /> LOD-I, CALIFORNIA 95241-0560 <br /> (209) 334-5144 <br /> FAX (209)'333-1034 <br /> E <br /> October 12, 1994 <br /> Mr. Albert M.: Ellis <br /> Hakeem, Ellis& Simonelli <br /> Attorneys at Law <br /> 2800 W. March Lane, Suite 200 <br /> i Stockton, California 95219 <br /> Re: Giannoni" v. Lehr, et al . <br /> Ellis-:.. ... . <br /> I am in receipt of your correspondence dated September 29, <br /> 1994, and, in that regard, my client is giving consideration <br /> to Mr. Giannoni ' s offer to settle the lawsuit in exchange <br />[ for the sum of $20, 000 . 00 . . I am unclear whether his permis- <br /> sion to perform the remediation on his property is contin- <br /> gent upon receipt of the $20, 000 . 00 and settlement of the <br /> lawsuit. <br /> Additionally,' ' the six-month tame limit remains impractical, <br /> as remediation by vapor extraction and air sparging some- <br /> times, but not always, takes significantly longer than this <br /> to attain acceptable levels. Nonetheless, the placement of <br /> equipment on this site would not in any way hamper or inter- <br /> .fere with the conduct of business at the A&W site. <br /> I trust that you. and Mr. Giannoni would agree that remedi- <br /> ation of the site is of first ,and foreost importance, and, <br /> m <br /> :as such, we would like to immediately begin the process with <br /> Mr. GiannoniIs permission.. <br /> By way of this letter, I am also informing you that I am <br /> ' - .„takingrMr; G arnoni,' s--depos,iL on -of--f-calendar,-originally <br /> `scheduled for October 19, 1994', to some other date accept- <br /> able to Mrs . .Madison' s attorney also. I am informed that <br /> t they will contact your office "and mine to arrange for a <br /> mutually agreeable date and time. <br /> f Please discuss the foregoing with your client and give me a <br /> I� call at your earliest convenience. <br /> Very truly yours' . <br /> r MULLEN, SULLIVAN & 7JEWTON' .. <br /> s by . -..� <br /> 'D:dm JAMES V.' DeMERA III <br /> cc: Mrs . Mary Lehr <br /> Ms. Mary Meays <br /> L. <br />