A Letter sent from attorney to Scenic Pit, LLC.

Dear Attorney McIlnay:

We understand that you represent Scenic Pit LLC and Thomas and Danah Zoulek (your “Client”) regarding your Client’s publicly stated intent to dump materials into the restored and vegetated former limestone quarry located on the above-referenced property (the “Property”). Many of your Client’s neighbors have formed a Wisconsin limited liability company, Richfield Residents Against Dump LLC (hereinafter, “RRAD”). We have been retained by, and now represent, RRAD and have been directed to take any and all legal measures to oppose any dumping of any materials on the Property.

We understand that your Client has not applied for, or received, any zoning, land use or erosion control approvals needed to conduct the proposed activity on the Property. We further understand that there was, on at least one occasion, earthmoving activity on the Property. Finally, we understand that your Client has commenced an action for a declaration of rights in Washington County Circuit Court, identified as case no. 15-CV-374 (the “Circuit Court Case”).

We demand that your Client immediately cease and desist any activity in any way associated with the preparation for, or acceptance of, dumping materials upon the Property, unless and until you receive all approvals required by law. Rest assured that we will oppose any rezoning or issuance of approvals to allow for the proposed offensive use. Unless it is your intent to abandon the plan to truck in material to dump on the Property, we will seek to intervene in the Circuit Court Case so that the voices of the many neighbors opposed to this dump will be heard.