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1 The above-indicated witness has the following matters or <br /> 2 things in her possession or under her control (specify exact <br /> 3 matters or things desired to be produced) : <br /> 4 The Department of Environmental Health's <br /> 5 entire file regarding the property located <br /> 6 at 140 W. Harding Way, Stockton, California. <br /> 7 The matters or things specified above are material to the <br /> 8 issues involved in this case by reason of the following facts <br /> 9 (set forth in full detail) : <br /> 10 The property jointly owned by Mr. Reade and <br /> 11 Mr. Tiscornia has not yet received a <br /> 12 clearance from the Department of <br /> 13 Environmental Health. <br /> 14 Good cause exists for the production of the matters or <br /> 15 things specified above in that: <br /> 16 Settlement of the matter between plaintiff <br /> 17 and defendant cannot be made until the status <br /> 18 of the 140 Harding Way property is resolved. <br /> 19 I declare under penalty of perjury that the foregoing is <br /> 20 true and correct and that this declaration is executed on <br /> 21 November dry , 1992 at Modest California. <br /> 22 <br /> ERIK R. ANDERSON <br /> 23 <br /> 24 <br /> 25 <br /> 26 <br /> 27 <br /> 28 2 <br />