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WILLIAM A. SCHUCKMAN <br />JUDITH A. FEINBERG <br />c_arl rlEc PYRGLEGOL <br />LAW OFFICES OF <br />WILLI.AINI A. SCHUCK- , <br />3031 WEST MARCH LANE <br />SUITE 123 SOUTH <br />ST0C:=0N, CALIFOMNIA 95219-6500 <br />May 16, 2000 <br />David J. Irey <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 />Thank you for your fax dated May 16, 2000. <br />TELEPHONE (209) a72-I)OC <br />FAX (209) 672-1079 <br />Via Facsimile Transmittal <br />1. Apparently I misunderstood your fax dated May 9, 2000. I interpreted your demand <br />that all correspondence to you be in writing to mean that under circumstances where notice would <br />ordinarily be by phone (such as notice of ex -parte applications) you required a writing, a writing that <br />could only be provided by fax. Perhaps my misunderstanding was reinforced by your failure -to <br />return my numerous phone calls. <br />I will comply with any phone notice requirements by phoning you. If you are unavailable. <br />I will leave them with your receptionist. Please be sure he or she forwards all messages to you <br />immediately. <br />2. I am unaware of more than one case against these defendants as only one case is_ <br />referenced in your letter dated May 9, 2000, to Mr. Ellis. <br />On May 8, 2000, I wrote you concerning CV 008909. If your response dated May 9, 20001 <br />was with respect to other cases, it did not so state. <br />Please immediately provide me with the case numbers of the other two cases you have filed <br />and with your proof of service of the Summons and Complaint on each defendant. If those cases <br />have been filed but not served, this office will accept service by fax. <br />3. A pleading that is vague and ambiguous is subject to attack by special demurrer, CCP <br />§ 430.10(f). Normally such a demurrer is not necessary as the attorneys can resolve an ambiguity LL <br />informally. Unfortunately, you have ignored at least five attempts by this office to reach an informal <br />resolution. <br />