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Dennis Fields, Assistant Coordinator Hazardous Materials Division <br />222 E. Weber Ave, Rm 610 <br />Stockton, CA 95202 <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 />California Health and Safety Code, Chapter 6.95, Article One does not base its <br />definition of hazardous materials on PPM. <br />7. If your response to Interrogatory No. 6 above is in the affirmative, state each fact on which <br />you base that contention. <br />You can find the Health and Safety Code definition of a hazardous material in <br />Section 25501 (o) and (p). <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 <br />No. 6 above. <br />Dennis Fields, Assistant Coordinator Hazardous Materials Division <br />222 E. Weber Ave, Rm 610 <br />Stockton, CA 95202 <br />9. If your response to Interrogatory No. 6 above is in the affirmative, identify each document <br />(as defined in Ev. Cd. 250) which you contend supports each fact stated in response to <br />Interrogatory No. 6 above. <br />California Health and Safety Code, Chapter 6.95, Article One. <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 />Dennis Fields, Assistant Coordinator Hazardous Materials Division <br />222 E. Weber Ave, Rm 610 <br />Stockton, CA 95202 <br />11. (Omitted) <br />12. Have you ever measured the amount of Carbon Dioxide handled at any facility operated by <br />Proprietary Pizza or George Badway? <br />Yes <br />13. If your response to Interrogatory No. 12 above is in the affirmative, please identify by date <br />and location each occasion on which you measured such quantity. <br />1304 E. Hammer Lane <br />12/16/98 11/1/99 7/12/2000 <br />