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r <br /> ORRICK <br /> June 8, 2009 <br /> Page 2 <br /> Our previous document requests, sent on May 29, 2009,included requests for all documents.and <br /> communications relating to the regular maintenance of the lagoons, the waste management system, <br /> and the waste or manure management plan including all current or prior versions. We expect to <br /> receive documents related to this recent removal of waste from the lagoon in response to those <br /> document requests. We will also propound additional discovery requests related to this event <br /> shortly. <br /> As we still contend that these actions constitute destruction of evidence,we repeat our request that <br /> Olivera inform us no later than Tuesday June 9, 2009 at 5:00 p.m. of the steps taken to preserve the <br /> physical evidence, through scientific testing or other means, of the areas on its property that <br /> Plaintiffs have already notified Olivera it intends to inspect. <br /> Very truly yours, <br /> Nicole A. Roth <br /> cc: Russ J. Wunderli <br /> Joshua Watts <br /> Hilarie Link <br /> Angela Padilla <br /> Jessica Culpepper <br /> Peter Brandt <br /> SanJoaquin County,Public Health Services, Environmental Health Division (VIA U.S..__- <br /> MAIL ONLY) <br /> OHS West:260673707.2 <br />