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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 />organizations unless the information is equally available to the propounding parry pursuant to <br />Section 2030(f)(1) of the California code of Civil Procedure. <br />SPECIAL INTERROGATORIES <br />1. Do you contend that a concentration of 4000 parts per million (PPM) gas Carbon <br />Dioxide in a properly -ventilated, customer -occupied room at a business facility constitutes an <br />immediate danger to the life of persons occupying that room? <br />2. If your response to Interrogatory No. 1 above is in the affirmative, state each fact on <br />which you base that contention. <br />3. If your response to Interrogatory No. 1 above is in the affirmative, identify by name, <br />address and telephone number each witness to each fact stated in response to Interrogatory No. 2 <br />I above. <br />4. If your response to Interrogatory No. 1 above is in the affirmative, identify each <br />document (as defined in Ev. Cd. 250) which you contend supports each fact stated in response to <br />Interrogatory No. 2 above. <br />5. If your response to Interrogatory No. 1 above is in the affirmative, identify by name, <br />address and telephone number each custodian of each document identified in response to <br />Interrogatory No. 4 above. <br />6. Do you contend that a concentration of gas Carbon Dioxide of 4000 parts per million <br />(PPM) in a properly -ventilated, customer -occupied room at a business facility constitutes an <br />immediate danger to the health of persons occupying that room? <br />7. If your response to Interrogatory No. 6 above is in the affirmative, state each fact on <br />which you base that contention. <br />8. If your response to Interrogatory No. 6 above is in the affirmative, identify by name, <br />address and telephone number each witness to each fact stated in response to Interrogatory No. 6 <br />above. <br />9. If your response to Interrogatory No. 6 above is in the affirmative, identify each <br />document (as defined in Ev. Cd. 250) which you contend supports each fact stated in response to <br />Special Interrogatories to Plaintiff <br />People of the State of California <br />-2- <br />