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I McDONOUGH,HOLLAND &ALLEN <br /> +- L <br /> AProfessional Corporation n"'-^r s ocr,7oia <br /> 2 JOHN R.STEPHEN MG ERNER, tate ES . ESQ. (S Bar <br /> te Bar No. 176688) 00 NO' - I r"ii 3: 3G- <br /> 3 <br /> G3 555 Capitol Mall, Ninth Floor <br /> Sacramento, California 95814 <br /> 4 Telephone: 916-444-3900 <br /> Facsimile: 916-444-8334 1 1 <br /> 5 EP <br /> ury <br /> Attorneys for Defendants <br /> 6 <br /> 7 <br /> 8 SUPERIOR COURT OF CALIFORNIA <br /> 9 COUNTY OF SAN JOAQUIN <br /> 10 <br /> 11 PEOPLE, ex rel.,CENTRAL VALLEY ) Case No. CV 007544 <br /> REGIONAL WATER QUALITY CONTROL ) <br /> 12 BOARD AND THE DEPARTMENT OF ) DECLARATION OF RON <br /> TOXIC SUBSTANCES, ) SILVERIA IN SUPPORT OF <br /> 13 ) DEFENDANTS' OBJECTIONS TO <br /> Plaintiffs, ) PLAINTIFFS'PROPOSED <br /> 14 ) DECISION <br /> V. ) <br /> 15 ) Date: November 8,2000 <br /> BRUCE KIMBROUGH,JOANNE M. ) Time: 10:00 A.M. <br /> 16 KIMBROUGH,JOE J.MACHADO and ) Dept: 42 <br /> LILLIAN E. MACHADO, ) <br /> 17 <br /> Defendants. <br /> 18 ) <br /> 19 l: I am one of the owners of J.R. Laser Finishing, a licensed general <br /> 20 contractor specializing heavy equipment operation for earthmoving. I have personal <br /> 21 knowledge of the facts stated herein, and if called to testify, could and would <br /> 22 confidently testify thereto. <br /> 23 2. My company has extensive experience in the construction of manure <br /> 24 retention ponds for dairies. Our firm has constructed approximately 25 such ponds <br /> 25 over the last 10 years. We average of two or three ponds per year. <br /> 26 3. Approximately three weeks ago during the first week of October 2000, I <br /> • 27 was contacted by Bruce Kimbrough to inspect the Lucky "J" Dairy (the "Dairy") in <br /> 28 order to discuss construction of improvements at the Dairy, including two retention <br /> Declaration of Ron Silveria in Support of Defendants'Objections to Plaintiffs'Proposed Decision <br />