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L E 7 8 9 10 11 12 3) That I have personally handled several hundred hazardous material files; '- 4) That the majority of the hazardous material files I have handled involve violations of Chapter 6.95 of the Health and Safety Code as it relates to hazardous materials management plans; 5) That I am familiar with the Office of Emergency Services procedures and policies; 6) That I have filed over 100 civil environmental enforcement cases with similar circumstances to this matter; 7) That I have used this general complaint for over 10 years; 8) That I have never been questioned about the charging language being ambiguous; 9) That dozens of defense counsel have reviewed the(--�mplaints; 10) That each of the San Joaquin County Judges currently assigned to the Civil Division has signed numerous stipulations and/or defaults using the language contained in this; 11) That I have been the prosecutor throughout this investigation; 12) That I have met with and explained the complaints to two separate defense counsel in this matter, prior to Mr. Schuckman becoming involved; 13) That during one of those meetings, with Mr. Albert Ellis, Mr. Badway was present; 14) That during that meeting with Mr. Albert Ellis and Mr. Badway present, I explained the violations of the law as they related to gaseous carbon dioxide; 15) Further, that during that meeting, I was present when both Dennis Fields and Robert Lopez from San Joaquin County Office of Emergency Services were questioned by Mr. Albert Ellis. The Office of Emergency Services employees explained the entire chronology of events to both gentlemen and informed them of the gaseous carbon dioxide issues; 16) That an agreement was reached at the meeting regarding all three cases; 17) That I drafted the stipulations and injunctions for those cases and forwarded them for ,ignature to Mr. Ellis; 18) That I was at a conference the week of May 2-5, when Mr. Schuckman began to call iaily; 19) That immediatley, upon getting the message, either on May 3rd or May 4th, I ttempted to contact the attorney whom I had settled these cases with, Mr. Ellis; 13 e!7 14 15 16 17 18 19 20 21 22 23 24 25 26 i l' ' 27 28 a 3) That I have personally handled several hundred hazardous material files; '- 4) That the majority of the hazardous material files I have handled involve violations of Chapter 6.95 of the Health and Safety Code as it relates to hazardous materials management plans; 5) That I am familiar with the Office of Emergency Services procedures and policies; 6) That I have filed over 100 civil environmental enforcement cases with similar circumstances to this matter; 7) That I have used this general complaint for over 10 years; 8) That I have never been questioned about the charging language being ambiguous; 9) That dozens of defense counsel have reviewed the(--�mplaints; 10) That each of the San Joaquin County Judges currently assigned to the Civil Division has signed numerous stipulations and/or defaults using the language contained in this; 11) That I have been the prosecutor throughout this investigation; 12) That I have met with and explained the complaints to two separate defense counsel in this matter, prior to Mr. Schuckman becoming involved; 13) That during one of those meetings, with Mr. Albert Ellis, Mr. Badway was present; 14) That during that meeting with Mr. Albert Ellis and Mr. Badway present, I explained the violations of the law as they related to gaseous carbon dioxide; 15) Further, that during that meeting, I was present when both Dennis Fields and Robert Lopez from San Joaquin County Office of Emergency Services were questioned by Mr. Albert Ellis. The Office of Emergency Services employees explained the entire chronology of events to both gentlemen and informed them of the gaseous carbon dioxide issues; 16) That an agreement was reached at the meeting regarding all three cases; 17) That I drafted the stipulations and injunctions for those cases and forwarded them for ,ignature to Mr. Ellis; 18) That I was at a conference the week of May 2-5, when Mr. Schuckman began to call iaily; 19) That immediatley, upon getting the message, either on May 3rd or May 4th, I ttempted to contact the attorney whom I had settled these cases with, Mr. Ellis;