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c •s <br /> JQHN Office of the District Attorney <br /> PX INVESTIGATIONS DIVISION <br /> DIS°�RICT ATTORNEY 37 Hunter Square <br /> San Joaquin County Telephone:(209)468-3620,Stockton, 0 California 9520 d <br /> SUBJECT: BILL LANE, SR. <br /> TYPE OF CASE: EPU (ATTORNEY ASSIST) <br /> FILE NO: 92-919 <br /> LEGAL NO: M90-114877 <br /> (W) Kerman Meyer, Attorney for defendant <br /> (W) Tom Sweezo, Code Enforcement Officer, San Joaquin County <br /> Per request of Deputy District Attorney Irey, and at the <br /> request of Judge Abdallah, I was assigned to assess the type of <br /> materials in the landfill area located on Lane's property at 23201 <br /> South Santa Fe Road, Escalon, CA. <br /> On September 15, 1992, I met with Mr. Meyer, Sweezo, and the <br /> defendant Lane at the location. I checked the landfill area and a <br /> small portion that had been excavated. I discovered the following <br /> items which were visible: <br /> Large pieces of concrete, asphalt, lumber, plywood, galvanized <br /> pipe, black pipe, cast iron pipe, pvc pipe, ' sheet aluminum, <br /> sheetrock, copper wire, plastic sheeting, burned stumps and tree <br /> limbs. I also observed what appeared to be asbestos pipe material <br /> on the surface of the filled area, and pieces of asbestos that had <br /> been uncovered by the excavation. <br /> In order to realize what material was used to create the <br /> landfill, the entire area would have to be excavated. This would <br /> result in the removal of hundreds of yards of material. <br /> On September 16, 1992, I appeared at the Escalon Court before <br /> 1 <br />