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APEL & ESTEPE

Attorneys at Law

MEMORANDUM

TO: Applicant

FROM: Lou Estepe

SUBJECT: Tehama County v. Tepee Campground

DATE: July 29, 2014

________________________________________________________________

We represent Jane Maya, who owns and operates Tepee Campground. Jane was
served with a Notice to Abate by the County Attorney’s Office of Tehama County. We have an
abatement hearing scheduled. The abatement hearing is a trial before an independent
administrative law judge.

Before I write my brief, please draft an objective memorandum that discusses and
analyzes the charges made in the Notice to Abate, and evaluates our chances of prevailing
against each charge. Take into consideration arguments likely to be made by the County. A
separate statement of facts is not necessary. Instead, use the facts in your analysis of the
charges.

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