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'j I until he returns the office furniture and equipment to Francis. 2 B. Alexander Should Be Held in Contempt for Interferingwith Francis' <ffQrJS ta `r 3 Clean up Environmental Hazards Qn the Pranerty 4 Alexander has also violated this Court's orders by interfering with Francis' efforts to clean up the S environmental hazards on the Property. 6 The Stipulated Preliminary Injunction specifically enjoined Alexander from interfering with i 7 Francis' access to or possession of the Property. This Court's Temporary Restraining Order, dated 8 February 27, 1995, further enjoined Alexander from"interfering with Francis and his representatives' 9 unrestricted right to access to any portions of the Premises,take photographs and samples," and from .� 10 "touching, or coming within fifty (50) feet of, any tanks,barrels or drums on the Premises." In addition, J 11 on February 27, 1995,this Court personally admonished Alexander not to interfere in any way with 12 Francis' efforts to clean up the environmental hazards on the Property. 13 As set forth in the attached declarations, Alexander has completely ignored this Court's Ory clear 14 and specific instructions, and has gone out of his way to frustrate Francis' efforts to clean up the 15 dangerous environmental conditions on the Property.:Alexander has actively prevented Shephard from l 16 disposing of hazardous materials, and Alexander has so intimidated and threatened Shephard that neither -� 17 Shephard nor his company, Valley Environmental Solutions, Inc.,will provide any further services ,J, 1$ elated to the Property. See She hard Declaration, and 6. Alexander has also so interfered with � p rty� E P ��,� ) � 19 efforts to deal with the caustic soda that California Tank Lines, Inc_, which was originally willing,to 20 remove the caustic at no cost to Francis, is no longer willing to provide any services whatsoever. (See 21 Ellis Declaration, 5.) Alexander's interference has resulted in damages to Francis in that, whereas the 22 caustic soda was going to be removed at no cost, Francis will now have to pay to have the caustic hauled 23 to a facility and disposed of. 24 Alexander's interference has been deliberate and blatantly contemptuous, and has effectively .25 prevented Francis from cleaning up the environmentally dangerous conditions on the Pi'bperty. 26 C. The Preliminary Injunction Should Be Modified to Immediately Remove Alexander .E 27 from the PrqVeM 28 Most significantly, there is strong circumstantial evidence to indicate that Alexander intentionally 3