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X413-� FiDAVID ORNEY Oa MRTY MTNW T AMJ NEV/&.—.rM/pp wy/� rELEPNONE NO: 100 COU,rr USE O.vrY A. RISIIWAIN (0157134) (209) 473-2800 RISHWAIN 6 RISIIWAIN 2800 W. March Lane, Suite 220 Stockton, California 95219 AnoRNEY FOR/N.m,/ Plaintiff, JOHN and KERRY GIANNONT NAyE OE covm� SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN STREET ADDRESS JOAQUIN MAILING ADDRESS- 222 E. Weber Avenue ClY AND ZIP CODE- Stockton, California 95202 I ANC.,NA/aL PLAINTIFF/PCTITIONER: JOHN CIANNONI and KE , DEFENDANT/RESPONDENT EMMAGENE MADISON and MARY LEHR DEPOSITION SUBPENA rASE NUM6ER For Production of Business Records 251725 THE PEOPLE OF THE STATE OF CALIFORNIA, TO Internal: Custodian of Records of San Joaquin County Public Health Services, Environmental Health Division 1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in item 3 as follows: Deposition Officer Inamel: Major Legal Services - - Date: February 28, 1997 Time: 10.00 a.m. Address: 1333 Hove Avenue, Suite 211 - acramento. CA 95825 Do not release the requested records to the deposition officer prior to the date and time stated above. a. I by delivering a true legible, and durable copy of the business records described in item 3.enclosed in a sealed inner wrapper with the title and number of the action. name of witness, and date of subpena clearly written on it- The inner wrapper shall then be enclosed in an outer envelope or wrapper, sealed, and mailed to the deposition officer at the address in item 1. b. O by delivering a true. legible and durable copy of the business records described in item 3 to the deposition officer at the wit- ness's address,on receipt of payment in cash or by check of the reasonable costs of preparing the copy,as determined undo, Evidence Code section 1563(b). C. O by making the original business records described in item 3 available for inspection at your business address by the attorney's representative and permitting copying at your business address under reasonable conditions during normal business hours. 2. The records are to be produced by the date and rime shown in item 1 /but not sooner than 20 days after the issuanee of the deposition subpena,or 15 days afrerservice, whiche rerdate is lared.Reasonable costs oflocatingrecords,making them available or copying them, and postage, if any, are recoverable as set forth in Evidence Code section 1563Ibl. The records shall be accompanied by an affidavit of the custodian or other qualified witness pursuant to Evidence Code section 1561. 3. The records to be produced are described as follows: See Attachment 3. ® Continued on attachment 3. DISOBEDIENCE OF THIS SUBPENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE FOR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY. Date issued: January 4g-, L997 II David. A. Rishvain �r� sh.w _-'' __._—_--.. 1$ MATUR[Or PERSON ISSU,NG SLIDNI Attorney for Plaintiffs (See reverse for proof of service) ., r.........._.... .. . ._. nCnn CiTlnwl Cl rnnr•Ma m,r..•�r�r ---- --