Letter regarding Site Access Agreement
NANCY D'ANNA ATTORNEY AT LAW S33O P.O. BOX** CRUZ BAY ST. JOHN, U.S. VIRGIN ISLANDS 00831 (809) 776-6533 FAX (809) 776-6260 September 6, 1994 »y *«l«fax: (809) 776-8520 Kevin D'Amour, Esq. D'A»our, Jones, Stryker & Duensing Drake's Passage Box 6785 St. Thomas, USVI 00804 Re: Site Access Agreement Dear Attorney D'Amour: It is my understanding that Ms. Caroline Kwan, from the United States Environmental Protection Agency has discussed our request for access to Mrs. Harvey's property to remediate any contamination which may be present. It is my understanding that Mrs. Harvey would like further explanation of our intended activities and has requested that I forward this explanation to you. L'Henri, Inc. has hired International Technology, Corporation, a nationally recognized firm, to prepare the Workplan which was previously forwarded to your office and to perform the work. The area which will be excavated is approximately 10 square feet. Only a portion of the excavation is to be performed on Mrs. Harvey's property. …
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NANCY D'ANNA ATTORNEY AT LAW S33O P.O. BOX** CRUZ BAY ST. JOHN, U.S. VIRGIN ISLANDS 00831 (809) 776-6533 FAX (809) 776-6260 September 6, 1994 »y *«l«fax: (809) 776-8520 Kevin D'Amour, Esq. D'A»our, Jones, Stryker & Duensing Drake's Passage Box 6785 St. Thomas, USVI 00804 Re: Site Access Agreement Dear Attorney D'Amour: It is my understanding that Ms. Caroline Kwan, from the United States Environmental Protection Agency has discussed our request for access to Mrs. Harvey's property to remediate any contamination which may be present. It is my understanding that Mrs. Harvey would like further explanation of our intended activities and has requested that I forward this explanation to you. L'Henri, Inc. has hired International Technology, Corporation, a nationally recognized firm, to prepare the Workplan which was previously forwarded to your office and to perform the work. The area which will be excavated is approximately 10 square feet. Only a portion of the excavation is to be performed on Mrs. Harvey's property. As described in the plan, the excavation will be filled with clean soil. As per the Site Access Agreement, in the unlikely event of injury as a result of the work, my client w i i l indemnify arid hold Mrs. Harvey harmless from any and all damage which may result. EPA oversight will be provided for all aspects of the project. The soil will be stored at the 0'Henry Dry Cleaning facility in accordance with applicable CFR regulations. These regulations require a caged area, on top of a concrete slab and protection from rain and the elements. Finally, it is my understanding that Mrs. Harvey has complained that she has not received water deliveries. However, my office has received invoices for water deliveries to Mrs. Harvey's property in excess of $500.00 for the month of August, 1994. Please contact my office at your earliest convenience if the water invoiced was not delivered, or if Mrs. Harvey has experienced any difficulty obtaining water. TUT 007 1125 *64959* 64959 I have attempted, without success, to contact your office by telephone to ascertain if you are assisting Mrs. Harvey in this matter, or if other counsel has been retained. Please let me know if we should direct our request for access to another office. Your attention to this matter is appreciated. Please contact ray office at your earliest convenience in order that we might discuss this matter further. Sincierely, \O Nancy D'Anna, Esq. ND/aw cc : Caroline Kwan Andrew Prashak, Esq. . - TUT 00.