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JOHN -11 <br />PHILLIPS <br />DISTRICT ATTORNEY <br />San Joaquin County <br />March 15, 1999 <br />ATTN LEIGH HOLMES <br />LEIGH HOLMES SALES <br />20075 N HWY 99 <br />ACAMPO CA 95220 <br />Re: Application for Complaint <br />tce of the District Attorney <br />San Joaquin County Courthouse, Rm. 202 <br />222 E Weber Ave. Stockton, California 95202 <br />P.O.Box 990, Stockton, California 95201 <br />Telephone:(209) 468-2400 <br />An application for a complaint has been made to this office by the San Joaquin County Office of <br />Emergency Services alleging your violation of specific sections of Chapter 6.95 of the California <br />Health and Safety Code. The general requirements of this chapter concern completion of a business <br />emergency plan and inventory and the completion of a risk management plan if a business handles <br />acutely hazardous materials. The Office of Emergency Services has contacted your business on the <br />specifics of your business' requirements and has made numerous administrative attempts to obtain <br />compliance with these legal requirements. <br />In order that no injustice be done, a decision as to the filing of charges by this office has been delayed <br />until your statement of the facts regarding this alleged violation is received. Therefore, please contact <br />this writer to discuss the specific alleged violations at (209) 468-2470 no later than <br />March 25, 1999. <br />In the event you do not contact this office, we shall assume that the facts stated by the complainant are <br />correct and will file a complaint. <br />You may wish to consult with an attorney and have an attorney attend all meetings with this office. <br />As your business may be incorporated, an attorney will have to sign for the corporation if any <br />agreements are reached in this matter. <br />Sincerely, <br />OFFICE OF THE DISTRICT ATTORNEY <br />DAVID J. IREY <br />Deputy District Attorney <br />Environmental Prosecutions Unit <br />c: Office of Emergency Services <br />