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(77 <br />WILLIAM A. SCHUCXMAN <br />JUCITH A. FEINBERG <br />CrIp.M tED PARALEGAL <br />San Joaquin County <br />Office of Emergency Services <br />222 East Weber Avenue, <br />Room 610A <br />Stockton, CA 95202 <br />Attention: Dennis L. Fields . <br />LAW OFFICES OF <br />WII T.T &moi A. SC -UCS;3 <br />3031 WEST MARCH LANE <br />SUIT£ 123 SOUTH <br />sTOCg'TON, Cg1,IFOHNLi 95219-6500 <br />July 14, 2000 <br />Re: Pro rietary Pizza dba Eddde's Pizza Cafe <br />Dear Mr. Fields: <br />TELEPHONE (209) 472-1100 <br />FAX (209) 472-1079 <br />As you know this office represents George Badway and Proprietary Pizza Corporation in <br />connection with a Government claim that VIr. Badway handles sufficient quantities of Carbon <br />Dioxide to trigger various regulatory requirements. <br />We have learned that you. a criminal investigator and a Mr. Robert Lopez visited some of <br />Proprietary Pizza's facilities on July 12, 2000, and, without a warrant, did some sort of inspection <br />of tanks that may contain Carbon Dioxide. <br />Initially, we have no objection to proper regulatory visits. if however, you ou conducting <br />bta n <br />a criminal investigation (and thus require a criminal investigator such as Mr. Allen), y <br />a search warrant. <br />With respect to your "Hazardous Materials Program Inspection Forms" we have both <br />comments and questions. <br />1. CoComments: <br />1.1 ivir. Badway informs me that you refused to allow him to sign or notate the forms in <br />any way or to discuss those reports with him. <br />1.2 You have prepared two contradictory reports for the Hammer Lane restaurant. <br />