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11'14/97 FRI 10:25 FAX 425 257 8741 CITY OF EVERETT BUILDING l2l oo: <br />DREG WDONNELL SARGEANT iY GILLETT PLLC <br />LAWYERS <br />Mark F. O'Donnell <br />RiecieIV <br />November 12, 1997 NOV 4 QED <br />Gry <br />OF <br />qrY cIERKkTi <br />Ms. Sharon Marks <br />Clerk, City of Everett <br />3002 Wetmord Ave. <br />Everett, WA 982U 1 <br />Re: Freudenbera v. Donald Morin, Inc. <br />This firm represents Don Morin of DMI, Inc. Mr. Morin's company constructed a <br />Duralagg retaining wall on property owned by Darrel Freudenberg located at 4937 Seabreeze <br />Way. The work started in approximately July of 1993 and was completed in late September of <br />1993. The wall was designed by Paul Weber of Meta Engineering. <br />Mr. Freudenberg is suing Mr. Morin. We enclose herewith a Notice of Records <br />Deposition and a Subpoena Duces Tecum to obtain all records in the care, custody or control of <br />the City of Everett relating to work performed at the Freudenberg property. This requires <br />production of all records in the care, custody or control of the City of Everett, including records <br />in the possession of the Building Department or any other department or agency that would be <br />involved in the permit process. Essentially, we want every piece of paper in the City's care, <br />custody or control relating to work performed at Mr. Freudenberg's property, including but not <br />limited to the cons,ruction of the Duralagg retaining wall. <br />We can forego the formality or the deposition process if the City will simply copy and <br />produce its files, and execute the enclosed declaration. We will reimburse the City for <br />photocopying charges. <br />The case is scheduled for arbitration in December. The records deposition is scheduled <br />for November 24. We can forego the need for the records deposition if the City agrees to <br />provide me with the records by that date. In the event that there are no such records in <br />existence, then the records custodian needs to so indicaie on the enclosed declaration. <br />THE FINANCIAL CENTER, ELITE 920 • M5 FOURTH AVENUE • SE.iTFLE, U'ASHINCTON 95161-I:: A <br />TELEPHONE (2N) 187-1775 • FACSIMILE (106) 257-9113 <br />