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JOHNOffice of the District Attorney <br /> PHILLIPS San Joaquin County Courthouse,Rm.202 <br /> 222 E.Weber Ave.,Stockton,California 95202 <br /> DISTRICT ATTORNEY P.O.Sox 990,Stockton,California 95201 <br /> San Joaquin County Telephone: (209)468-2400 <br /> February 11, 2004 FAX: (209)465-0371 <br /> Syed Hussian <br /> Denny's Restaurant <br /> 5033 S. Hwy 99 <br /> Stockton, CA. 95215 <br /> Re: Application for Complaint <br /> An application for a complaint has been made to this office by the San Joaquin County Office of <br /> Emergency Services alleging your violation of specific sections of Chapter 6.95 of the California <br /> Health and Safety Code. The general requirements of this chapter concern completion of a <br /> business emergency plan and inventory and the completion of a risk management plan if a <br /> business handles acutely hazardous materials. The Office of Emergency Services has <br /> contacted your business on the specifics of your business' requirements and has made <br /> administrative attempts to obtain compliance with these legal requirements. <br /> Your business has previously been the subject of prosecution by this office for a <br /> violation of these statutes. As a result of that prosecution, an Order was entered by the <br /> court requiring the timely filing of the business plan each year. Failure to file this plan <br /> now constitutes a separate violation of that court order, which will be prosecuted in <br /> addition to any violation for the current year. <br /> In order that no injustice be done, a decision as to the filing of charges by this office has been <br /> delayed until your statement of the facts regarding this alleged violation is received. Therefore, <br /> please contact Diane Grover to schedule a meeting regarding these issues at (209) 953-7748, <br /> no later than February 20, 2004. <br /> In the event you do not contact this office, we shall assume that the facts stated by the <br /> complainant are correct and will file a complaint. <br /> You may wish to consult with an attorney and have an attorney attend all meetings with this <br /> office. As your business may be incorporated, an attorney will have to sign for the corporation if <br /> any agreements are reached in this matter. <br /> Sincerely, <br /> OFFICE OF THE DIS CT ATTORNEY <br /> VID J. IR <br /> Lead Deputy istri Attorney <br /> Environmental rosecutions Unit <br /> cc: Office of Emergency Services <br /> Tata Foods Corp. <br /> Eric G. Dzubur, attorney at Law <br />