BAUER, Circuit Judge.
In 1988, Crow Chicago Industrial, Inc. and McWane, Inc. entered into a limited partnership agreement to redevelop property located in Carol Stream, Illinois. The agreement included a Letter of Understanding regarding a due diligence investigation of the property. Crow hired Halff Associates, Inc., an environmental consulting firm, to conduct an environmental audit. On January 7, 1998, McWane filed suit against Crow and Halff to recover the
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