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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />W-1 <br />PRELIMINARY STATEMENT <br />As of this date, Plaintiff has neither completed discovery nor its investigation of the facts in <br />this case. The information contained in these responses therefore reflects only what is known and <br />available up to the current date. Plaintiff reserves the right to produce and utilize other things <br />discovered at a later date, and the following responses are given without prejudice to the Plaintiffs <br />right to produce subsequently discovered responses. Accordingly, Plaintiff reserves the right to <br />change any and all of the following responses as additional information is located and analyses and <br />contentions made. This preliminary statement is incorporated by reference into each of the <br />responses set forth hereinafter. <br />The current responses are submitted in a good faith effort to comply with Defendant <br />PROPRIETARY PIZZA CORPORATION, ET AL.'s requests. No documents protected by the <br />attorney-client, attorney work product, right of privacy, official information and/or government <br />privilege will be produced. The foregoing objection ("privilege objections") are incorporated by <br />reference into each of the responses set forth hereinafter. <br />The Office of the District Attorney of the County of San Joaquin filed this action pursuant to <br />the statutory laws of the State of California, and on behalf of the People of the State of California. <br />The Office of the District Attorney (the "DA") does not represent state agencies, boards, <br />departments, commissions, employees, or officers. By statute, the causes of action asserted in this <br />matter were filed on behalf of the "People." For purposes of this Response, Responding Party is the <br />People of the State of California, by and through the District Attorney of the County of San Joaquin. <br />Documents of any other state agencies, boards, departments, commissions, employees, or officers <br />are not requested. <br />The answers and responses hereinafter given by Plaintiff are based upon information <br />presently known to Plaintiff and are without prejudice to producing at trial subsequently discovered <br />information or information omitted from the answers as a result of a good faith oversight. <br />SPECIAL INTERROGATORY NO. 1 <br />California Health and Safety Code, Chapter 6.95, Article One, does not define a hazardous <br />2 <br />