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SUSP-002 <br /> PLAINTIFFIPETITIONER: Joseph Panetta and Rosanna Panetta GSE NUMBER. <br /> CV 030599 (Consolidated) <br /> DEFENDANTIRESPONDENT. Chevron U.S.A.,Inc.,et al. <br /> The production of the documents or the other things sought by the subpoena m page one is supported by(check one): <br /> the attached affidavit or declaration m the following declaration: <br /> DECLARATION IN SUPPORT OF CIVIL SUBPOENA(DUCES TECUM)FOR PERSONAL <br /> APPEARANCE AND PRODUCTION OF DOCUMENTS AND THINGS AT TRIAL OR HEARING <br /> (Code CW.From,§§1085,1987.5) <br /> 1. 1,the undersigned.declare I am the = plaintiff defendant = petitioner 0 respondent <br /> attorney for(speefly):plaintiffs 0 other(specify): <br /> In the above-entitled action. <br /> 2. The witness has possession or control of the following documents or other things and shall produce them at the time and place <br /> specified in the CMI Subpoena for Personal Appearance and Production of Documents and Things at Dial or Hearing on page one <br /> of this form(specify the exact documents or other things to be produced): <br /> The files and records of the San Joaquin County Public Health Services -Environmental Health Division <br /> ("EHD"),including Units III and IV,pertaining to the property known as 103 West 11 th Street,Tracy, <br /> California,covering the period from June 1991 through and including the present,November 4,2010, <br /> including but not limited to all notes or entries entitled,labeled,described or characterized as <br /> "Confidential". <br /> 0 Continued on Attachment 2. <br /> 3. Good cause exists for the production of the documents or other things described in paragraph 2 for the following reasons: <br /> The documents are relevant and material to the issues raised by the instant action for continuing nuisance <br /> and continuing trespass involving the former Chevron site located at 103 West I 1 th Street,Tracy,and <br /> reflect the information provided by Chevron 10 and that was analyzed by the EHD relative to site <br /> assessment and remediation,if any,and the action taken by EHD in response. The originals of the files and <br /> documents are in the exclusive custody and control of the EHD and thus of its Custodian of Records. <br /> 0 Continued on Attachment 3. <br /> 4. These documents or other things described in paragraph 2 are material to the Issues Involved In this case for the following reasons: <br /> For the reasons noted in Section 3 above. <br /> =Continued on Attachment 4. <br /> 1 declare under penally of perjury under the laws of the State of California that the foregoing Is true and correct. <br /> Dale: November 4,2010 / <br /> ........._.......Robert .Kahn <br /> .................................................... <br /> (TYPE OR MWRwE) ISIGNATUREOF O SV Pp INGPARTY F,-' <br /> ATiORNEV F011 <br /> suBPGEWJNG <br /> Request for Accommodations <br /> Assistive IisteNng systems,computer-assisted reel-Uma captioning,or sign language Interpreter services are available <br /> if you ask at least five days before the dale on which you are to appear.Contact the clerk's carica or go to <br /> M,vw.rnurflnlo.ca.govAomu for Request for Accommodations by Persons With Disabilities and Response(form <br /> MC-410). (CIv#Code,§54.8.) <br /> (Proof or Service on page 3) <br /> suvP tin.J*1.7<10"1 CIVIL SUBPOENA(DUCES TECUM) FOR PERSONAL APPEARANCE P.y.S"ra <br /> AND PRODUCTION OF DOCUMENTS AND THINGS <br /> AT TRIAL OR HEARING AND DECLARATION <br />