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Supplemental response to motion for entry of Consent Judgment. This was our effort to bar the State of Oregon from lining its pockets at our expense. My company, Pacific III, LLC entered into a contract with the Oregon DEQ to purchase and clean up a property that was a former leather tannery and battery manufacturing plant. The contract with the State of Oregon allowed us to seek contribution from Potentially Responsible Parties. The state found out that Wells Fargo was responsible because bank officers actually oversaw the operation of the tanning operation and set up a trust to protect a wealthy family. The State of Oregon then entered into settlement negotiation with Wells Fargo, insurance companies, and others, and did not include me in the negotiations nor notify me until after the settlement was reached. They included portions of the property that I purchased and cleaned up and used the Consent Judgment process in order to bar me from seeking contribution from the Potentially Responsible Parties. The case is now at the Oregon Court of Appeals.