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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />LAW OFFICES OF <br />WILLIAM A. SCHUCKMAN <br />3031 West March Lane, <br />Suite 123 South <br />Stockton, CA 95219-6500 <br />CA State Bar No: 43080 <br />Telephone: (209) 472-1100 <br />Attorney for defendants, <br />PROPRIETARY PIZZA <br />CORPORATION, et al. <br />SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN <br />STOCKTON BRANCH <br />THE PEOPLE OF THE STATE OF <br />CALIFORNIA, <br />Plaintiffs, <br />vs. <br />PROPRIETARY PIZZA <br />CORPORATION, et al., <br />Defendants, <br />CASE NO: CV 008909 <br />DEFENDANTS' REPL Y TO <br />OPPOSITION TO DEMURRER <br />Date: July 11, 2000 <br />Time: 9:00 a.m. <br />Dept: #11 <br />1. Specificity of unit measure alleged: <br />After refusing to do so despite repeated written requests, plaintiffs in their Opposition <br />concede the point and specify that the alleged unit of measure is "cubic feet at standard temperature" <br />and that the only gas in question is Carbon Dioxide. <br />An amended complaint that is limited to Carbon Dioxide measured in cubic feet at an <br />unascertainable temperature at least forms a starting point for discovery. <br />2. Feigned Ignorance of Labor Code § 6382: <br />In their original demurrer, defendants miscited L. Cd. § 6382 as H & S Code 6382. <br />Plaintiff's counsel was clearly aware of the proper citation since he cited that statute himself in his <br />Opposition Brief. <br />Nonetheless, he failed to address the issue raised: Does the handling of a minuscule quantity <br />Defendants Reply to Opposition to Special Demurrer <br />and Memorandum in Support thereof <br />