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Dennis Fields, Assistant Coordinator Hazardous Materials Division <br />222 E. Weber Ave, Rm 610 <br />Stockton, CA 95202 <br />24. If your response to Interrogatory No. 21 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. 21 above. <br />California Health and Safety Code, Chapter 6.95, Article One <br />25. If your response to Interrogatory No. 21 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. 21 above. <br />Dennis Fields, Assistant Coordinator Hazardous Materials Division <br />222 E. Weber Ave, Rm 610 <br />Stockton, CA 95202 <br />26. 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 volume for which there is <br />valid and substantial evidence (as that phrase is used by you in Labor Code 6382) that any <br />adverse acute or chronic risk of human health may occur from exposure. <br />There was enough Carbon Dioxide present in cubic feet that it reached the <br />reporting requirements of the California Health and Safety Code, Chapter 6.95, <br />Article One. The Labor Code is invalid in the determination whether the material <br />is reportable under the Health and Safety Code for this regulation. <br />27. If our response to Interrogatory No. 26 above is affirmative, state each fact on which you <br />base that contention. <br />California Health and Safety Code, Chapter 6.95, Article One <br />28. If your response to Interrogatory No. 26 is in the affirmative, identify by name, address and <br />telephone number each witness to each fact stated in response to Interrogatory No. 26 <br />above. <br />Dennis Fields, Assistant Coordinator Hazardous Materials Division <br />222 E. Weber Ave, Rm 610 <br />Stockton, CA 95202 <br />29. If your response to Interrogatory No. W6 above is in the affirmative, identify each <br />document (as defined in Ev. Cd. 250) which you contend supports each fact stated in <br />response to Interrogatory No. 26 above. <br />California Health and Safety Code, Chapter 6.95, Article One <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 />