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A <br />WILLIAM A. SCHUCKMAN <br />JUOITH A. FEIN9ERG <br />C£RTIFICO PARALEGAL <br />LAW OFFICES OF <br />wILIJ -& Ni A.SCHIIC�tAIti <br />3031 WEST MARCH LANE <br />SUITE 123 SOUTH <br />STOCgT0:7. CAT-IFORw'Ia 95219-6500 <br />May 8, 2000 <br />David J. Trey <br />Deputy District Attorney <br />Environmental Prosecutions Unit <br />Post Office Box 990 <br />Stockton, CA 95201 <br />Re: People vs Eddie's Pizza Cafe, et al. <br />San Joaquin Superior Court No: CV 008909 <br />Dear Mr. Irey: <br />TELEPHONE (209) 472-IIOC <br />FAX (209) 472-1079 <br />Via Facsimile Transmittal <br />This office has been retained to represent Proprietary Pizza and George Badway in <br />connection with a lawsuit filed by you relating to his use of carbon dioxide at the pizza parlors. I <br />phoned your office on May 3, May 4 and May 5th but have received no call back. <br />We would like to preliminarily resolve two issues: <br />1. The date on which pleadings are due from the defense. A review of the file indicates <br />that the complaint was filed and served some time ago but that negotiations have been ongoing. <br />Unless I hear from you to the contrary in writing, I will assume that responsive pleadings may be <br />timely filed at any time through Mav ;0th. <br />2. Your complaint is fatally ambiguous in that it pleads alternative measures of quantity <br />alleged to trigger certain safety plan requirements. Such disjunctive pleadings are inherently vague <br />and ambiguous and subject to demurrer. Rather than go through that drill, I propose that you simply <br />advise me which of the numerous alternative units you are actually alleging. We can then file a <br />stipulated amendment clarifying that issue. Please advise. <br />WAS/if <br />CC: Mr. George Badway <br />Yours very truly, <br />WILLIAM A. SCHUCKMAN <br />�xNIBIT L <br />i Sgt <br />