Laserfiche WebLink
May- 16-00 03 : 23P P _ 02 <br /> LAW OFFICES OF <br /> WILLIAM A. SCHUCKMAN <br /> 3031 WEST MARCH LANE TELEPHONE (209) 472-1100 <br /> WILLIAM A. SCHUCKMAN FAX (2091 47a-1079 <br /> SUITE 123 SOUTH <br /> JUOITH A. FEIN6ERG STOCKTON, CALIFORNIA 95219-GSOO <br /> CGR7, ICO PA Y�LCGAL <br /> May 16, 2000 <br /> David J. Irey Via Facsimile Transmittal <br /> Deputy District Attorney <br /> Environmental Prosecutions Unit <br /> Post Office Box 990 <br /> Stockton, CA 95201 <br /> Re: People vs Eddie's P17za 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 /> 1. Apparently I misunderstood your fax dated May 9, 2000. 1 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, 2000, <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 <br /> informally. Unfortunately, you have ignored at least five attempts by this office to reach an inforrr.al <br /> resolution. <br />