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1 1. On January 16, 1991 Ed Padilla an employee of the <br />2 Environmental Health Department sent a letter to David Irey of <br />3 the San Joaquin County District Attorneys Office. The letter <br />4 discussed the site disposition and the necessary actions that <br />5 must be taken to resolve the issues at the site (See Attachment <br />6 G) . <br />7 M. On February 4, 1991 Bill Lane pled Nolo <br />8 Contendere to charge of violating the San Joaquin County <br />9 Ordinance Code Section 9-4005.1. As part of the agreement Bill <br />10 Lane was to turn over the soil on the property, soil brought in <br />11 by defendant 25 percent per year, is to be sifted for hazardous <br />12 construction materials which are to be removed (See Attachment <br />13 H) . <br />14 n. The Environmental Health Department received a <br />15 copy of a report, dated September 17. 1992. The report was <br />16 written by Dean Hendricks an investigator for the District <br />17 Attorney Office. The report accounts a site visit to the <br />18 subject property and documented a list of types wastes found <br />19 during an excavation at the site (See Attachment I). <br />20 0. A criminal complaint was filed against Bill Lane, <br />21 DA Case: COM 0172494, on November 6, 1992 for the illegal <br />22 disposal of hazardous waste on the subject property (See <br />23 Attachment J) . <br />24 p. On October 2, 1992, a Search Warrant was issued <br />25 for the subject property. The warrant yielded 18 photographs, 1 <br />26 sample of material from a drum, 1 soil sample (See Attachment <br />27 K) . <br />28 <br />Inspection Warrant <br />- 6 - <br />