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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 />Interrogatory No. 6 above. <br />10. If your response to Interrogatory No. 6 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. 6 above. <br />11. (Omitted) <br />12. Have you ever measured the amount of Carbon Dioxide handled at any facility <br />operated by Proprietary Pizza or George Badway? <br />13. If your response to Interrogatory No. 12 above is in the affirmative, please identify <br />by date and location each occasion on which you measured such quantity. <br />14. With respect to each measurement identified in response to Interrogatory No. 13 <br />above, please state whether the method of measurement used by you was approved by the San <br />Joaquin Department of Weights and Measures. <br />15. With respect to each measurement identified in response to Interrogatory No. 13 <br />above, describe the exact method of measurement used. <br />16. With respect to each measurement identified in response to Interrogatory No. 13 <br />above state the exact weight of Carbon Dioxide you measured to be present at each referenced <br />location. <br />17. With respect to each measurement identified in response to Interrogatory No. 13 <br />above state the exact volume of Carbon Dioxide you measured to be present at each referenced <br />location. <br />18. With respect to each volume stated in response to Interrogatory No. 17 above, state <br />the exact pressure of the Carbon Dioxide that occupied that volume. <br />19. With respect to each volume stated in response to Interrogatory No. 17 above, state <br />the exact number of gallons of the Carbon Dioxide that occupied that volume. <br />20. State the unit of measure you apply in measuring Carbon Dioxide for purposes of <br />determining whether you require a Carbon Dioxide handler to submit a Hazardous Materials <br />Management Plan. <br />Special Interrogatories to Plaintiff <br />People of the State of California <br />-3- <br />