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Pertaining To: RAYMOND INVESTMENT CORPORATION V. HELENA CHEMICAL
<br />COMPANY
<br />You must produce the following documents in accordance with the Federal Rules of Civil
<br />Procedure.
<br />Request for Production No. 1
<br />All documents—for example, and without limitation—citations, complaints, notes,
<br />photographs, investigations, reports, plans, interviews, correspondence, electronic
<br />communications, emails, texts, pdfs, electronic media, films, certificates of compliance, permits,
<br />discovery prepared, regardless of whether it was propounded, and discovery responses, expert
<br />witness reports, or things of any kind or nature suitable for presentation as evidence—relating to
<br />the operation, use, and/or condition of the property located at 2245 West Charter way, Stockton,
<br />San Joaquin County, California before the year 1995.
<br />Request for Production No. 2
<br />All documents—for example, and without limitation—citations, complaints, notes,
<br />photographs, investigations, reports, plans, interviews, correspondence, electronic
<br />communications, emails, texts, pdfs, electronic media, films, certificates of compliance, permits,
<br />discovery prepared, regardless of whether it was propounded, and discovery responses, expert
<br />witness reports, or things of any kind or nature suitable for presentation as evidence—relating to
<br />the operation, use, and/or condition of the property located at 2245 West Charter way, Stockton,
<br />San Joaquin County, California after the year 2002.
<br />WESW79037558
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