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• <br />Hessian Attorneys at Law <br />& McKasy P.A. <br />MAR i 9 a <: <br />March 18, 1999 <br />Thomas M. Sweeney, Esq. <br />Sweeney, Borer & Sweeney <br />Suite 1200 <br />386 North Wabasha Street <br />St, Paul, Minnesota 55102 <br />Re: Schnitzer Iron & Metal Site <br />Demand Letter <br />4700 IDS Center <br />80 South Eighth Street <br />Minneapolis, Minnesota 55402 -2228 <br />(612) 330-3000 Fax (612) 371-0653 <br />Joseph G. Maternowski <br />(612) 330 -3010 <br />jmaternowski@hessian.com <br />Dear Mr, Sweeney: <br />I am writing in response to your March 1, 1999 letter relating to the City of Little <br />Canada's liability related to the Schnitzer Iron & Metal Site located in the Highway 280 area <br />between Minneapolis and St. Paul. <br />Our claim is based, in part, on the weight ticket that documents the transaction between <br />Little Canada and Schnitzer Iron & Metal. As I indicated to you in our conversation, the <br />Minnesota Pollution Control Agency (MPCA) relied on the Schnitzer weight tickets to establish <br />liability under the Minnesota Environmental Response and Liability Act (MERLA) against over <br />75 other parties at the site. By its own admission, the MPCA failed to identify hundreds of <br />parties at the site. The Schnitzer Group relied on the same documentation the MPCA used to <br />identify numerous other parties including Little Canada. <br />By way of background, the MPCA made its initial claim against 75 parties, One of the <br />group of parties that were identified were units of government. The following parties were <br />named: the Cities of Minneapolis, St. Paul, St. Anthony, Shoreview, North St. Paul, Apple <br />Valley, Centerville, White Bear Lake, and Ramsey County. Our search for parties has yielded <br />the names of Little Canada and several other municipalities. ' <br />The MPCA's claim against municipalities and other parties was based on the same <br />weight ticket evidence that we have presented to your client in our demand. I am enclosing a set <br />of weight tickets, for the Cities of Apple Valley, North St. Paul and St. Anthony for your review. <br />As you can see, these tickets specify the name of each of the entities without further identifying <br />information such as the words "City of or an address. Each of these parties settled their liability <br />Page 123 <br />"d E S W02id 141d6S E 666 L -6 L —E <br />