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AL J. CONE <br />WARD WAGNEP, JR. <br />CHARLES A. NUGENT, JR. <br />ROBERT R.JOHNSON <br />FRED A. HAZOURI <br />DAVID ROTH <br />ROBERT C. RO55 <br />JOHN F. ROMANO <br />EDWARD M. RICCI <br />LAWRENCE M. KUKEY <br />BARBARA J. PARIENTE <br />LOUIS MARC SILBER <br />MICHAEL A. NUGENT <br />MELINDA PENNEY GAMOT <br />RICHARD A. KURFER <br />MICHAEL D.ERIKSEN <br />A. CLARK CONE <br />October 27, <br />-'N OFFICES <br />CONE, WAGNER, NT7(.L1:-. ,JOHNSON,IL1zo1_ rZr R RU•rn <br />1 <br />1982 <br />PROFEQS=-)NAL ASSOC]ATTON <br />507 NZ=TH OLIVE AVENUE <br />POS- =='fICE BOX 3466 <br />WEST PAL(! ._EAG, 1, FLORIDA 33402 <br />TELEP-_•,E (305) 655-8100 <br />ISLE: MCOWN <br />Gary Brandenburg, Esquire <br />Indian River County Attorney <br />Vero Beach, FL 32960 <br />Re: Judge Stikelether <br />Dear Mr. Brandenburg: <br />It has come to my attention tint there may be <br />tigation of my client going on at the present <br />suggested to me that this "investigation" may <br />to expose my clients to certa--: types of toxic <br />thereafter to gauge their reaction to same by <br />them or other means. <br />FLAGLER CENTER OFFICE <br />SOI SOUTH FLAGLER DRIVE,SUITE 202 <br />WEST PALM BEACH. FLORIDA 33402 <br />TELEPHONE 1305) 655 8100 <br />9[ <br />some type of inves- <br />time. It has been <br />include some effort <br />substances and <br />either photographing <br />You have, or should have by this time in your possession a letter <br />from Dr. Feldman which indicaes beyond any doubt that these par- <br />ticular clients are definitely- sensative to certain substances <br />and that the condition they have is a very serious condition. In <br />light of that, I would view anv effort to intentionally expose <br />them to certain types of substances to gauge their reaction to same, <br />as an intentional effort to wreak injury upon them. Such being the <br />case, as you know, the person= responsible would be individually <br />liable for punitive damages, i^ that I am sure that the County has <br />not authorized them to carry c_t such actions. Hence, their <br />individual and separate liabi__ty. <br />I would certainly appreciate fz if you would give me a call upon <br />your receipt of this letter tc assure me that my concerns, as <br />expressed herein, are unfounded. If there is any substance to <br />them, however, I am equally s: -=e that you will take immediate <br />steps to have these persons cease and desist. <br />Sincerely, <br />MICHAEL D. ERIKSEN 1. <br />MDE/j lr <br />cc: Judge Graham Stikelether <br />Ward Wagner, Jr., Esquire <br />Nov 3 1982 68 <br />seox 51 PAVE 895 <br />Noir 1, rs <br />9[ <br />some type of inves- <br />time. It has been <br />include some effort <br />substances and <br />either photographing <br />You have, or should have by this time in your possession a letter <br />from Dr. Feldman which indicaes beyond any doubt that these par- <br />ticular clients are definitely- sensative to certain substances <br />and that the condition they have is a very serious condition. In <br />light of that, I would view anv effort to intentionally expose <br />them to certain types of substances to gauge their reaction to same, <br />as an intentional effort to wreak injury upon them. Such being the <br />case, as you know, the person= responsible would be individually <br />liable for punitive damages, i^ that I am sure that the County has <br />not authorized them to carry c_t such actions. Hence, their <br />individual and separate liabi__ty. <br />I would certainly appreciate fz if you would give me a call upon <br />your receipt of this letter tc assure me that my concerns, as <br />expressed herein, are unfounded. If there is any substance to <br />them, however, I am equally s: -=e that you will take immediate <br />steps to have these persons cease and desist. <br />Sincerely, <br />MICHAEL D. ERIKSEN 1. <br />MDE/j lr <br />cc: Judge Graham Stikelether <br />Ward Wagner, Jr., Esquire <br />Nov 3 1982 68 <br />seox 51 PAVE 895 <br />