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Mr. Robert McClellon <br />June 15, 2012 <br />Page 6 <br />As just the latest instance of unlawful landfill operations, the recent <br />activities on the proposed expansion site reinforce the notion that Forward is either <br />incapable or unwilling to obey the law. The County has a duty to enforce all laws, <br />regulations, and permits governing the operation of Forward Landfill. <br />III. California Public Records Act Request <br />This letter also constitutes a California Public Records Act request for any <br />records in the possession of San Joaquin County, including but not limited to the San <br />Joaquin County Environmental Health Department and the San Joaquin County <br />Community Development Department, related to: <br />(1) Any and all violations or alleged violations of any federal, state, or local law, <br />regulation, or permit resulting from activity on the Forward Landfill proposed expansion <br />site, located to the south and west of the existing Forward Landfill; <br />(2) Local Enforcement Agency investigation and enforcement of any and all <br />violations or alleged violations referenced in Request (1), including investigation reports <br />and notes; <br />(3) Any meetings or communications, including electronic communications, <br />between the County and Forward, Inc., or their representatives or affiliates, regarding any <br />and all violations or alleged violations referenced in Request (1). <br />We respectfully request that the County's response be expedited. Please <br />also inform me when the County expects to be able to respond to this request. We may <br />choose to send our own service to copy any records made available, so please do not <br />incur any expenses in regards to this request without first contacting us. A Public <br />Records Release Application accompanies this letter. <br />SHUTE MIHALY <br />'-WEINBERGERLLP <br />