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I PRELIMINARY STATEMENT 2 As of this date, Plaintiff has neither completed discovery nor its investigation of the facts in 3 this case. The information contained in these responses therefore reflects only what is known and 4 available up to the current date. Plaintiff reserves the right to produce and utilize other things 5 discovered at a later date, and the following responses are given without prejudice to the Plaintiffs 6 right to produce subsequently discovered responses. Accordingly, Plaintiff reserves the right to 7 change any and all of the following responses as additional information is located and analyses and 8 contentions made. This preliminary statement is incorporated by reference into each of the 9 responses set forth hereinafter. 10 The current responses are submitted in a good faith effort to comply with Defendant 11 PROPRIETARY PIZZA CORPORATION, ET AL.'s requests. No documents protected by the 12 attorney-client, attorney work product, right of privacy, official information and/or government 13 privilege will be produced. The foregoing objection ("privilege objections") are incorporated by 14 reference into each of the responses set forth hereinafter. 15 The Office of the District Attorney of the County of San Joaquin filed this action pursuant to 16 the statutory laws of the State of California, and on behalf of the People of the State of California. 17 The Office of the District Attorney (the "DA") does not represent state agencies, boards, 18 departments, commissions, employees, or officers. By statute, the causes of action asserted in this 19 matter were filed on behalf of the "People." For purposes of this Response, Responding Party is the 20 People of the State of California, by and through the District Attorney of the County of San Joaquin. 21 Documents of any other state agencies, boards, departments, commissions, employees, or officers 22 are not requested. 23 The answers and responses hereinafter given by Plaintiff are based upon information 24 presently known to Plaintiff and are without prejudice to producing at trial subsequently discovered 25 information or information omitted from the answers as a result of a good faith oversight. 26 SPECIAL INTERROGATORY NO. 1 27 California Health and Safety Code, Chapter 6.95, Article One, does not define a hazardous 28 2