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LAW OFFICES OF <br /> WILLIAM A. SCHUCgMAN <br /> WILLIAM A. SCHUCKMAN 3031 WEST MARCH LANE TELEPHONE (209) 472-1100 <br /> FAX (209) 472-1079 <br /> SUITE 123 SOUTH <br /> JUDITH A. FEINSEPG <br /> CERTIFIED PARALEGAL SToC=ON, CAT-TFOB.NZA 95219-6500 <br /> July 14, 2000 i L" <br /> J& 2 6 20oo <br /> SanJoaquinJoaquin County <br /> Office of Emergency Services <br /> 222 East Weber Avenue, <br /> Room 610A <br /> Stockton, CA 95202 <br /> Attention: Dennis L. Fields . <br /> Re: Proprietary Pizza dba Eddie's Pizza Cafe <br /> Dear Mr. Fields: <br /> As you know this office represents George Badway and Proprietary Pizza Corporation in <br /> connection with a Government claim that Mr. Badway handles sufficient quantities of Carbon <br /> Dioxide to trigger various regulatory requirements. <br /> We have learned that you, a criminal investigator and a Mr. Robert Lopez visited some of <br /> Proprietary Pizza's facilities on July 12, 2000, and, without a warrant, did some sort of inspection <br /> of tanks that may contain Carbon Dioxide. <br /> Initially,we have no objection to proper regulatory visits. If, however, you are conducting <br /> a criminal investigation(and thus require a criminal investigator such as Mr.Allen),you must obtain <br /> a search warrant. <br /> With respect to your "Hazardous Materials Program Inspection Forms" we have both <br /> comments and questions. <br /> 1. Comments: <br /> 1.1 Mr. Badway informs me that you refused to allow him to sign or notate the forms in <br /> any way or to discuss those reports with him. <br /> 1.2 You have prepared two contradictory reports for the Hammer Lane restaurant. <br />