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F E 8 6 1301 <br /> 1 JOHN D. PHILLIPS ENVIRONMENTAL HEALTH <br /> District Attorney PERMIT/SERVICES <br /> 2 San Joaquin County <br /> By: LISA F. BROWN - #99150 <br /> 3 Deputy District Attorney <br /> Environmental Prosecutions Unit <br /> 4 P.O. Box 990 <br /> Stockton, CA 95201 <br /> 5 EPU:TAGGART3 <br /> 6 Telephone: (209) 468-2400 <br /> 7 Attorneys for Plaintiff <br /> 8 <br /> SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN <br /> 9 <br /> The People of the State of California, ) No. <br /> 10 ) <br /> Plaintiff, ) DECLARATION OF <br /> 11 ) LETITIA RESCH <br /> v• ) IN SUPPORT OF <br /> 12 ) PRELIMINARY <br /> CAMPBELL TAGGART, INC. et al. ) INJUNCTION <br /> 13 ) <br /> 14 Defendants. ) <br /> 15 I, LETITIA RESCH, declare: <br /> 16 1. I am a Registered Sanitarian and work for the San <br /> 17 Joaquin County Department of Public Health Services, <br /> 18 Environmental Health Division. <br /> 19 2 . I have personal knowledge of the following facts and <br /> 20 am competent to testify as to the truth of these facts if called <br /> 21 as a witness. <br /> 22 I conducted an inspection at the Earthgrain facility <br /> 23 located at 2651 South Airport Way, Stockton, on July 27, 1990, <br /> 24 due to a complaint received from Mr. Dennis Fields, Office of <br /> 25 Emergency Services. This complaint concerned two hazardous <br /> 26 conditions Mr. Fields found during a routine business license <br /> 27 inspection. The hazardous conditions were reported as follows: <br /> 28 1) a spill of acid liquid with a ph of 1 and 2) waste oil <br /> 1 <br />