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• • '-' BRAY, GEIGER, RUDQUIST & NUSS ATTORNEYS AT LAW DENNIS DONALD GEIGER,. I n 1 J 400 BANK OF STOCKTON BUILDING FOUNDED 1882 JOHN B.RUDOUIS7 `.` ') 311 EAST MAIN STREET MARKS.BRAY,OF COUNSEL JAMES T.C.NUSS' STOCKTON, CALIFORNIA 95202-2904 FRANK ANTHONY S.GUERRIERI) MELVIN..ORR(851-1916) MELVIN H.ORR(1851-1916) ALAN R.COON TELEPHONE(209)948-0434 STEVEN P.EMRICK W.B.NUTTER(1859-1939) FACSIMILE (209)948-9451 NEWTON RUTHERFORD(1881.1956) PETER A.VIRI LAUREEN J.KEEN E-MAIL BGRN@INREACH.00M D.R.JACOBS(1892-1970) STEPHEN DIETRICH(1908-1971) PHILIP CAVALERO(1907-1992) June 17, 1998 Via Facsimile (209) 464-0138 Mr. Steve Mindt County of San Joaquin 304 East Weber Avenue, 31 Floor Stockton, California 95202 Dear Mr. Mindt: This office represents Cal State Mortgage Co., Inc.,the owner by foreclosure on that property in Riverbank, commonly known as 23023 Santa Fe Road, Riverbank, California. It has come to my attention that the County is attempting, yet again,to file an action for cleanup on the property. It is quite apparent that the County targeted this property when it learned that the lien previously filed against the County proved unenforceable as to Cal State. I am also informed that the County's selected clean up crew purposely left some of the tires on the property so that there would be no easy access to the property. In other words,the County's agents purposely left the very same problem which they are now attempting to claim was not cleaned up by Cal State Mortgage, which only recently acquired the property through foreclosure. Furthermore, I am informed and believe that a Notice of Substandard Building is still recorded on the property. In addition, we are informed that certain County officials have been making derogatory comments and statements regarding saleability of the property to prospective brokers and buyers. Such contact interferes v4th the contractual rights that Cal State has with these parties. In short,the County is interfering with potential contracts of sale. Therefore, I must ask that you cease and desist,release the Notice of Substandard Building and refrain from further targeting of this property. You may confirm your response by directing a letter to the undersigned by no later than Friday, June 19, 1998. My fax number is (209) 948-9451. Sincerely yours, BRAY, GEIGER,RUDQUIST &NUSS By Ala chard Coon ARC:lh cc: Cal State Mortgage Co., Inc.