Your letterhead

25th April, 2019


JKL Construction Services Inc.

Santa Clara Valley Medical Center

San Jose, CA 95128


Build Group

457 Minna Street

San Francisco, CA 94103


Dear Sirs,

Re: unfair and deceptive acts by JKL Construction Services Inc (“JKL”) and its agents

I refer to the above matter and address you as hereunder:

As you are well aware, both JKL and CMI were contracted by the Santa Clara Valley Medical Center to offer their respective professional services. On its part, CMI has continuously, through its appointed agents, acted as an Inspector of Record for the Medical Center.


In discharging their duties, our agents have always acted in a professional, respectful and decorous manner towards your agents and all other persons. That is in line with our guiding principles and common decency. However, this has not been reciprocated by you and your agents.  In the recent past, we have been constrained to write to you demanding your agents’ apology and retraction of certain unfounded false statements made by them about CMI and its agents. These facts are well within your knowledge.


It has recently come to our attention and knowledge you and your agents are still unfairly and unlawfully targeting our agents at the Medical Center. Specifically, you have been making false allegations against our Denise East and other agents/staff. We are also aware that you have, on various occasions, asked the Medical Center’s management to terminate the engagement the Medical Center has with us and our agents.


Your actions and conduct in totality is unlawful and amounts to common law violations, including fraudulent misrepresentation and fraudulent inducement, unconscionability, and breach of the implied covenant of good faith and fair dealing on your part.


In view of the foregoing, we now write to demand your immediate admission of liability for the allegations set out above and that you immediately cease and desist from interfering with our relationship with the Medical Center and our operations at the Medical Center.


Unless we receive your reasonable written confirmation of compliance with the above conditions within the seven (7) days of this letter, we shall have no option but taking action to institute legal proceedings seeking for compensation and/or other redress for your unjustified inducement of breach of contract and defamation of character. We trust this can be avoided and accordingly hope to receive your written confirmation of compliance within the above stipulated period of time.


Roger M. Lenz,

CMI Contractors Inc.

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