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RICHARD MEYERS. P. A. <br />ATTORNEY AT LAW <br />1716 YbNX AY,NY[ <br />BT. PAUL. MINNESOTA 53112 <br />18121 HI•U„ <br />August 9, 1988 <br />Mayor and City Council of <br />the City of Mounds View <br />2401 Highway 10 <br />Mounds View, MN 55112 <br />ATTN: Donald F. Pauley <br />Re: Representation Re: Williams Pipe Line matters <br />Dear Mayor and Council Members: <br />This is to confirm our understanding with the City of. Mounds <br />View relative to the representation of the City by William <br />Foster, Eric Valen and the writer in the Williams Pipe Line <br />case versus City of Mounds View. <br />The City is engaged in litigation with Williams regarding <br />the explosion that occurred in the City on July 8, 1986, <br />when Williams Pipe Line IIN ruptured causing injuries, <br />t death, pollution and property damage. Since that date the <br />City has been engaged in lengthy and complex litigation with <br />Williams in the United States Federal Court. The City seeks <br />to have that portion of the pipeline that passes through it <br />removed or replaced and, also, to recover for damages to <br />City property and punitive damages. The City also seeks to <br />recover its expenses under Federai law or other proceedings <br />which to date total approximately $192,000.00, not including <br />property damages in an estimated amount of $60,000.00. <br />To date attorney's fees paid to Eric Valen and the writer <br />reflect approximately 1,800 hours ai work at $50.00 per <br />hour, or $90,000.00. <br />The attorneys, Eric Valera, William Foster and the writer, <br />hereby undertake to continue to represent the City on the <br />following basis -- <br />--From any monies received by way of verdict or settlement: <br />1. The City shall first recover any expenses paid by <br />it. <br />2. The City shall next recover actual property damages <br />as the result of the explosion and fire. <br />