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7. At no point during my discussions with Mr. Olivera was there ever any mention of <br /> litigation with Plaintiffs. <br /> 8. The purpose of the operation to dredge the manure lagoon was to increase lagoon <br /> volume, improve lagoon health and reduce the odors over time,an issue of immediate importance to <br /> the local residents and the Environmental Health Department. <br /> 9. It is my recollection that the Mr.Olivera did not want to start work on the lagoon until <br /> after the Memorial Day holiday,May 25,2009,due to concerns that it might cause additional impacts <br /> to the neighbors during the holiday. <br /> 10. Mr. Olivera's initial plan required new PVC piping to be installed to extend the <br /> discharge points of manure from the southern end of the lagoon to the northern portion of the lagoon. <br /> The affect was a discharge of manure into a more northern location of the lagoon,in an attempt to de- <br /> water the southern end of the lagoon. Other than the new PVC extensions,the existing PVC piping <br /> remained intact. Mr.Olivera's plan included being able to operate equipment inside the lagoon to do <br /> a more complete removal of the manure and grit (reach the manure and grit in the center of the <br /> lagoon). The excavation began in the southern end of the lagoon and soon after it was determined that <br /> the lagoon contained more liquid than originally thought. The site operation was scaled back to <br /> include excavation around the edges of the lagoon only. The manure and grit in the center of the pond <br /> would have to remain. <br /> 11. I was present at the Olivera ranch on Tuesday, June 2, 2009, when the operation to <br /> dredge the manure lagoon of sludge and grit began. Initially, only the excavator was onsite. I <br /> observed sludge and grit removed from the manure lagoon and placed in an area south of the lagoon <br /> that was bermed. I returned on June 3,and June 5,2009,to check the status of the excavation process <br /> and to check for fly breeding and odors. During the site visits, I was able to observe the excavator <br /> place the very liquid-like material in the dump trucks,and the dump trucks carrying the material to the <br /> 00707962.WPD 3 <br /> DECLARATION OF ROBERT MCCLELLON <br />