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S <br /> ' LAW OFFICES OF - <br /> __ HARDIN, COOK. LOPER. ENGEL & BERGEZ. LLP <br /> effamm RAYT90Np J, KRG� LAKE MERRITT PLAZA JIiNN1FER M. WALKER <br /> RALPH A.~�in. LAKE <br /> L. KOTZEBUE <br /> GANORA s. WAGNER 1999 HARRISON STREET, EIGHTEENTH FLOOR AMES A. MIRUICICH <br /> [LSA M. GALOWIN <br /> r1"INAD L. or"J wr OAKLAND. CALIFORNIA 94612-3541 T*MOTHY J. Mec"FERY <br /> STEPHEN MWAS STEPHEN A. FILICE STEPHEN J. YALEN , <br /> TROY O. "GMAHAN <br /> GRI/Ct r. R FAC*IMI1..E- (510) 639-7940 OAYLVNN R. KIRN <br /> E' hoeL a RICHARD Y. NORMINGTON <br /> Euena is M• (510) 444-3131 LISA M. GROWN <br /> WOVA O. ROOCNpUSE• O <br /> RLIAN <br /> JASON J. CU <br /> YATTNEW R CONANT RACHEL t. RLLAN <br /> OHM P. LAYOIOTIS MACK <br /> STEVEN K. LEE <br /> ROS O. 911SIA KERIN M. GUETERSLOH <br /> PETER G. GLAC11 NER JAMES S. KNOPF <br /> JOHN A. 09 PAGOk1AL.E LYNN S. SAMUELS <br /> ERLAWAYMANPETER A.StRTz Wy 7T 1996 <br /> JOHN c. LOP[ <br /> ASLG[R-LCK LY PARTNER EMEwM <br /> TUS <br /> OWE"T. ROONEY <br /> MAIN ALL A. JOHNWN J. MARCUS HARDIN [1908.19921 <br /> DIANE R. STANTON HERMAN COOK(1914-1982) <br /> OF COUNSEL <br /> •SS+SM�S�GSISw,EflYth wYNllll�Tir+FRSMSiJw RONALO A. WAGNER <br /> lllY <br /> We MMM sI Ld"SF.dstmMn RACHEL K. ANORESS <br /> Mark O. Kasanin <br /> MCCUTCHEN, DOYLE, BROWN A EMERSON <br /> 3 Embarcadero Center <br /> San Francisco, CA 94111 <br /> Re: Remedia#on Projecc- 305 S. Hutchins, Lodi, California <br /> Dear Mr. Kasanin: <br /> I have been informed that you represent Texaco R&M, Inc. in regard to the subject of <br /> remediation of toxic substances at the above-referenced property. As you may be aware, our <br /> firm has been retained by the owner of that property to advise her about the "conditional" <br /> closure letter which has been suggested concerning that property. On April 2, 1996, we <br /> provided the FDIC with a suggested Hold Harmless Agreement. In turn, they indicated that <br /> they would pass that agreement on to you and the other defendants to their litigation. <br /> Enclosed is another copy of that agreement. I have been contacted by representatives of San <br /> Joaquin County who indicate to me that they,will not issue a conditional closure without my <br /> client's approval. From her perspective, she does not intend by this action to unreasonably <br /> delay your withdrawal from the project. Nonetheless, she does want some measure of <br /> protection should a public agency reopen this property for remediation in the future. <br /> Since your client obviously believes that there is very little likelihood that any future <br /> remediation would be required, the remoteness of your exposure under the indemnity <br /> agreement would seem to indicate that entering into the agreement would be advantageous <br /> given the remoteness of the risk that you would be undertaking. Our office has been <br /> involved in litigation involving other petroleum commies who have been willing to grant <br /> this type of protection to property owners. - <br />