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Mr. Timothy Kong <br /> April 17, 2007. <br /> Page 4 of 4 <br /> In short, our client has done everything that you should have been doing to fix the <br /> problem with your property. This work-which is to your benefit as the owner of the <br /> property—has been very expensive. It would not have been necessary if you had not <br /> broken the contract you made with the County. <br /> In fact, it appears that you are the only one who will have a benefit from the repair <br /> of this property, since you are the current owner.' And, you are the only one who has <br /> possible rights for grant money to fix your property. <br /> Therefore, you as the current owner have a legal and equitable duty to our client <br /> to reimburse our client for her,expenses and to indemnify her for any future expenses she <br /> may incur. To date, our client has incurred over$25,000 in expenses in dealing with a <br /> problem that you,as the current property owner, should have fixed a long time ago. She <br /> will continue to incur more expenses—which you will have to pay-unless we can reach <br /> an agreement with you about our client's.claim. <br /> We suggest that you immediately notify your insurance carriers of this matter and <br /> seek the advice of competent legal counsel. <br /> Please contact us as soon as possible about our client's claim against you. If we <br /> do not hear from you by thirty(30) days from the date of this letter, we will take all <br /> necessary legal actions against you to obtain a court order requiring you to address the <br /> contamination issues and to recover our client's costs in dealing with the problem on your . <br /> property. ,. <br /> Very truly yours, / <br /> Jes R. Arnold <br /> Encls. <br /> Exhibit 1 — September 26, 2006 letter from RWQCB, with attached <br /> Chronology <br /> Exhibit 2—April 12, 2007 letter from RWQCB, with attached.draft Cleanup and <br /> Abatement Order <br /> Cc(w/o encls.): Client <br /> i <br />