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OVEN <br />C4�IFOaN�P <br />TO <br />FROM <br />SUBJECT: <br />COUNTY OF SAN JOAQUIN <br />OFFICE OF EMERGENCY SERVICES <br />ROOM 610, COURTHOUSE <br />222 EAST WEBER AVENUE <br />STOCKTON, CALIFORNIA 95202 <br />TELEPHONE (209) 468-3962 <br />HAZARDOUS MATERIALS DIVISION (209) 468-3969 <br />December 29, 2000 <br />David Irey, Environmental Prosecutions Unit <br />Dennis Fields, Emergency Services <br />RONALD E. BALDWIN <br />DIRECTOR OF <br />EMERGENCY OPERATIONS <br />RESPONSE TO EDDIE'S PIZZA SPECIAL INTERROGATORIES <br />Following is my response to the Special Interrogatories: <br />Do you contend that a concentration of 4000 parts per million (PPM) gas Carbon Dioxide <br />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 />California Health and Safety Code, Chapter 6.95, Article One does not base its <br />definition of hazardous materials on PPM. You can find the Health and Safety <br />Code definition of a hazardous material in Section 25501 (o) and (p). <br />2. If your response to Interrogatory No. 1 above is in the affirmative, state each fact on which <br />you base that contention. <br />California Health and Safety Code, Chapter 6.95, Article One Section 25503.5 <br />identifies the quantities that will be used to regulate businesses that handle or <br />store a hazardous material or a mixture containing a hazardous material <br />3. If your response to Interrogatory No.I above is in the affirmative, identify by name, address <br />and telephone number each witness to each fact stated in response to Interrogatory No. 2 <br />above. <br />Dennis Fields, Assistant Coordinator Hazardous Materials Division <br />222 E. Weber Ave, Rm 610 <br />Stockton, CA 95202 <br />4. If your response to Interrogatory No. 1 above is in the affirmative, identify each document <br />(as defined in Ev. Cd.250) which you content supports each fact stated in response to <br />Interrogatory No. 2 above. <br />California Health and Safety Code, Chapter 6.95, Article One. <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 />