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3 <br />4 <br />5 <br />6 <br />II <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 />30. If your response to Interrogatory No. 26 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. 26 above. <br />31. With respect to each measured quantity of Carbon Dioxide referenced in response to <br />Interrogatory No. 13 above, was the Carbon Dioxide present in a concentration for which there is <br />valid and substantial evidence (as that phrase is used by you in Labor Code 6382) that any adverse <br />acute or chronic risk of human health may occur from exposure. <br />32. State each fact that supports your contention at page 2, line 2 of your "Points and <br />Authorities in Opposition to Defendant's Special Demurrer" which stated the following: "With the <br />single exception of this defendant, all businesses which handle carbon dioxide in amounts over two <br />hundred (200) cubic feet comply with this statute." <br />33. Identify by name, address and telephone number each and every business referenced <br />by you at page 3, line 4 of your "Points and Authorities in Opposition to Defendant's Special <br />Demurrer" which reads as follows: <br />"With the single exception of this defendant, all businesses which handle carbon dioxide in <br />amounts over two hundred (200) cubic feet comply with this statute." <br />34. Please identify by complete name and case number each case in which a stipulated <br />judgment was entered as alleged on page 2, line 5 of your "Points and Authorities in Opposition to <br />Defendant's Special Demurrer" which reads as follows: <br />"As this court is aware, from signing numerous stipulated judgments and entering defaults, <br />every single business which has a known quantity of chemicals of reportable quantities must comply <br />with chapter 6.95 of the Health and Safety Code." <br />35. Please identify by complete name and case number each case in which a default was <br />entered as alleged on page 2, line 5 of your "Points and Authorities in Opposition to Defendant's <br />Special Interrogatories to Plaintiff <br />People of the State of California <br />-5- <br />