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h it l t dozen large tanks and approximately ninety (90) small containers on the Premises At the direction of W. :1 2 Francis' attorneys, I marked five (5) large stainless steel tanks as Tanks No. l throu-h >, and prepared a 3 map of the Premises depicting the location of various tanks and containers as described below (the 4 "Map"). A true and correct copy of the Map is attached hereto as Exhibit "A" and is incorporated herein 5 by reference. 6 4. 1 first visited the Property on February 9, 1995, accompanied by Leroy Francis' attorney, j 7 Michael F'luetsch. At that time, I determined that Tank No. 4 contained approximately four thousand i 8 (4,000) gallons of a toxic substance known as caustic soda. At the direction of Mr. Fluetsch, I took a :. 9 sample of the contents of Tank No. 4 for verification. George Alexander became very angry that I was 10 taking a sample of the contents of Tank No. 4, and yelled at me. 11 5. ' I again visited the Property on February 11, 1995, and determined that Tank No. 3 is a ten 12 thousandgallon tank containing a chemical known as Benzene, and that Tank No. 5 is a five thousand 13 gallon tank containing caustic soda. I took samples of the contents Tank Nos_ 3 and 5. 14 6. On February 20, 1995, I met Don Epps of California Tank Lines, Inc., at the Premises. Cal 15 Tank had agreed to haul away the caustic soda from Tank No. 4. However, Mr. Epps and I discovered 16 that Tank No. 4 was empty, and that the caustic soda had been spilled onto the ground. Mr. Alexander 17 approached me, and said that "thieves" had drained Tank No. 4. In light of the fact that the caustic soda 18 has obvi.o, sly sat undisturbed for more than ten years, and given ,Mr. Alexander's reaction to my taking a 19 sample of the caustic soda, I believe that the "spill" of the caustic soda was done by intentionally and 20 maliciously by Mr. Alexander. 1 :x 21 7. I am currently evaluating the environmental damage created by the caustic "spill", and 22 assessing what steps need to be taken to clean up the"spill". 23 8. If the "spill" had been of the Benzene in Tank No. 3, or one of the other ninety containers 24 stored on the Premises, it could have been a major environmental disaster. A spill of the Benzene in 25 particular would have been a major environmental catastrophe. Benzene is chemical commonly used as an 26 additive to gasoline. Benzene and its vapors are extremely toxic, highly flammable, and explosive. The i 27 vapors of Benzene alone are highly lethal. Federal Regulations classify Benzene as a carcinogen. These 28 risks are increased in this case, because testing of the Benzene sample by McCampbell Analytical Inc. has 73 2 5