9-10-18 cases

Page

Page 1 of 29

Filed 7/16/18

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION ONE

POST FOODS, LLC, et al.,

Petitioners,

THE SUPERIOR COURT OF

LOS ANGELES COUNTY,

Respondent;

RICHARD SOWINSKI,

Real Party in Interest.

B284057

(Los Angeles County

Super. Ct. No. BC516747)

ORIGINAL PROCEEDING; petition for writ of mandate.

Kenneth R. Freeman, Judge. Petition granted.

Arnold & Porter Kaye Scholer, Trenton H. Norris; Perkins

Coie, David T. Biderman and Eric D. Miller for Petitioners.

No appearance for Respondent.

Graham & Martin and Anthony G. Graham for Real Party

in Interest.

________________________________

Page 2 of 29

Petitioners Post Foods, LLC, General Mills, Inc., General

Mills Sales, Inc., and Kellogg USA, Inc. petition for a writ of

mandate directing the superior court to vacate its June 26, 2017

order denying their motion for summary judgment and issue an

order granting the motion. We issued a stay pending this Court’s

resolution of the petition and an order to show cause why a writ

of mandate should not issue.

Real party in interest Dr. Richard Sowinski’s complaint

alleges that Petitioners’ breakfast cereals were required by

California’s Proposition 65 to display cancer and reproductive

harm warnings because they contain acrylamide. Petitioners

contend such warnings on cereals are preempted by federal law

because they would pose an obstacle to federal policy objectives to

increase Americans’ consumption of whole grains. In support,

Petitioners cite to numerous federal statutes establishing that

policy, and Food and Drug Administration (FDA) letters to

California regulators cautioning against Proposition 65 warnings

on cereals because they could mislead consumers and cause them

to avoid whole grains, resulting in health detriments. Because

we agree that Dr. Sowinski’s Proposition 65 claim is preempted

by federal law, we grant the petition and direct the superior court

to vacate its order denying Petitioners’ motion and enter a new

and different order granting the motion.

FACTUAL AND PROCEDURAL BACKGROUND

Acrylamide has been produced artificially since the 1950’s

for industrial purposes, including the manufacture of various

polymers, cement, and for waste water treatment. Acrylamide

has been known to pose health risks for some time. It was added

to Proposition 65’s list of chemicals known to cause cancer in

1990, and later was determined to cause reproductive harm in

animal test subjects.

Page 3 of 29

In April 2002, Swedish researchers discovered that

acrylamide is generated naturally when carbohydrate-rich foods

are baked, roasted, fried, or deep fried. In particular, French

fries, potato chips, crackers, pretzel-like snacks, cereals, and

brown breads “tend to have the highest levels of [acrylamide].” A

2010 Environmental Protection Agency study noted, however,

that “since [acrylamide] appears to form from standard cooking

methods like baking, frying, and roasting, it has been in the

human diet for many thousands of years.”

Dr. Sowinski’s complaint alleges that 59 breakfast cereals

manufactured by Petitioners and sold in California contain

acrylamide, and therefore are required to include cancer and

reproductive toxicity warnings. He alleges that Petitioners’

failure to include such warnings violated the Safe Drinking

Water and Toxic Enforcement Act that Proposition 65 enacted.

At the outset of the case, the parties agreed to stay expert

discovery pending resolution of the Petitioners’ motion for

summary judgment on the threshold issue of whether Dr.

Sowinski’s claim is preempted by federal law.

Petitioners’ summary judgment papers included extensive

evidence that federal agencies have been studying the health

risks of acrylamide in food since it was discovered there in 2002.

The FDA has coordinated its studies with other federal agencies

and international science communities and is waiting until

scientifically sound risk assessments have been completed before

it determines what, if any, warnings are needed for acrylamide.

A. The FDA’s Guidance Regarding Acrylamide and

Proposition 65 Warnings

Beginning in 2003, the FDA corresponded with California’s

health agencies to advise against a Proposition 65 acrylamide

warning on food products because of its potential to confuse and

mislead consumers, and because a warning was likely to cause

Page 1 of 13

Filed 06/23/04

CERTIFIED FOR PARTIAL PUBLICATION∗

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FIVE

MICHAEL DiPIRRO,

Plaintiff and Appellant,

AMERICAN ISUZU MOTORS INC.,

et al.,

Defendants and Respondents.

A102961

(Alameda County

Super. Ct. No. 02-048648)

If a private plaintiff in a Proposition 651 lawsuit fails to provide a required

certificate of merit 60 days before filing the complaint, may that failure be cured by

providing the certificate after litigation has begun? In the published portion of this

opinion, we conclude that providing the certificate postlitigation is not a cure because it

impairs one method of achieving the statutory goal of reducing frivolous lawsuits.

Appellant Michael DiPirro appeals from an order of dismissal in favor of

respondents American Isuzu Motors Inc., Hyundai Motor America, Kia Motors America,

Inc., Mazda North American Operations, and Mitsubishi Motor Sales of America, Inc.,

pursuant to those respondents’ successful motion for judgment on the pleadings.

∗ Pursuant to California Rules of Court, rules 976(b) and 976.1, part II of this opinion is

not certified for publication.

1 The Safe Drinking Water and Toxic Enforcement Act of 1986. (Health & Saf. Code,

§ 25249.5 et seq.)

All undesignated section referenced are to the Health & Safety Code.

Page 2 of 13

Appellant contends the trial court erred in ruling that his failure to comply with the

prelitigation certificate of merit requirement under section 25249.7, subdivision (d)

mandated dismissal of his Proposition 65-based causes of action. We affirm.

BACKGROUND

Proposition 65 prohibits any person, in the course of doing business, from

knowingly and intentionally exposing any individual to a chemical known to the state to

cause cancer or reproductive toxicity without giving a specified warning, or from

discharging or releasing such a chemical into any source of drinking water, except as

specified. (§ 25249.5 et seq.)

Proposition 65 actions may be filed by public prosecutors or by private persons in

the public interest (hereafter, private enforcers). Since its adoption, Proposition 65 has

required a private enforcer to provide a 60-day notice of the violation that is the subject

of the action prior to commencing the action. This notice must be served on public

prosecutors and the violator. (§ 25249.7, subd. (d).) In 2001, the Legislature amended

this notice provision to require that, in cases claiming a failure to warn, the notice include

a “certificate of merit” stating that the private enforcer or his or her attorney consulted

with one or more experts who “reviewed facts, studies, or other data” regarding the

chemical exposure at issue, and believe “there is a reasonable and meritorious case for

the private action.” (Stats. 2001, ch. 578, § 1; see Sen. Rules Com., Off. of Sen. Floor

Analysis, 3d reading analyses of Sen. Bill No. 471 (2001-2002 Reg. Sess.) as amended

Sept. 13, 2001, coms., pp. 2-3.) The amendment (hereafter, Senate Bill No. 471) also

requires that factual information sufficient to establish the basis of the certificate of merit

be attached to the copy of the certificate served on the Attorney General.2 Senate Bill

2 As amended by Senate Bill No. 471, section 25249.7, subdivision (d) provides:

“(d) Actions pursuant to this section may be brought by any person in the public

interest if both of the following requirements are met:

“(1) The private action is commenced more than 60 days from the date that the person

has given notice of an alleged violation of Section 25249.5 or 25249.6 that is the subject

of the private action to the Attorney General and the district attorney, city attorney, or

prosecutor in whose jurisdiction the violation is alleged to have occurred, and to the

Page 3 of 13

No. 471 was prompted by a concern that private enforcers were abusing Proposition 65

by filing meritless lawsuits alleging that businesses had failed to provide adequate

warnings about chemical discharges. Senate Bill No. 471 was designed to discourage

such lawsuits. (See Sen. Rules Com., supra, coms. p. 2.) The legislation was approved

by the Governor in October 2001, and became effective January 1, 2002. (Stats. 2001,

ch. 578, § 1.)

In December 2001, between the Governor’s approval of Senate Bill No. 471 and

the amendment’s effective date, appellant filed 60-day notices with five automobile

companies that sell touch-up paint.3 No certificates of merit were included. These

notices recited that this product exposed people to toluene without proper warnings

concerning the toxic effects of such exposure. These December 2001 notices were also

served on the appropriate public enforcement agencies. On April 24, 2002, almost four

alleged violator. If the notice alleges a violation of Section 25249.6, the notice of the

alleged violation shall include a certificate of merit executed by the attorney for the

noticing party, or by the noticing party, if the noticing party is not represented by an

attorney. The certificate of merit shall state that the person executing the certificate has

consulted with one or more persons with relevant and appropriate experience or

expertise who has reviewed facts, studies, or other data regarding the exposure to the

listed chemical that is the subject of the action, and that, based on that information, the

person executing the certificate believes there is a reasonable and meritorious case for

the private action. Factual information sufficient to establish the basis of the certificate

of merit, including the information identified in paragraph (2) of subdivision (h), shall be

attached to the certificate of merit that is served on the Attorney General.

“(2) Neither the Attorney General, any district attorney, any city attorney, nor any

prosecutor has commenced and is diligently prosecuting an action against the violation.”

(Stats. 2001, ch. 578, § 1, italics added to reflect the provisions added by Sen. Bill No.

471.)

3 On the court’s own motion (Evid. Code, §§ 452, subd. (h), 459; see also Adoption of

Michele T. (1975) 44 Cal.App.3d 699, 706), we take judicial notice of the following

information: During the relatively brief period between the Governor’s approval (Oct. 5,

2001) of Senate Bill No. 471 and its effective date (Jan. 1, 2002), 3,696 60-day notices

were filed by private enforcers. This is approximately the same number (3,964) of such

notices filed by private enforcers in the more than 13 years preceding the Governor’s

approval of Senate Bill No. 471. (Cal. Off. of Atty. Gen., Programs & Services, 60-Day

Notice Search, at <http://prop65.doj.ca.gov/publicsearch.taf>.)

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starred, unread, Lana .. Wendy (11), Speak on the How to Create Prop. 56 Warnings for Internet Platforms at the Prop. 65 Conference, has attachments, Sep 18, Thank you, Leslie. I have added Joe to the attendee list. Wendy Wendy Crittenden Managing Editor wendy@prop65ch.com 415.385.4364 On Tue, Sep 18, 2018 at 3:49 PM Lana Beckett <lana@prop65ch.com>. Lana .. Wendy (11)	Conference 2018/Panels Speak on the How to Create Prop. 56 Warnings for Internet Platforms at the Prop. 65 Conference - Thank you, Leslie. I have added Joe to the attendee list. Wendy Wendy Crittenden Managing Editor wendy@prop65ch.com 415.385.4364 On Tue, Sep 18, 2018 at 3:49 PM Lana Beckett <lana@prop65ch.com>	Sep 18
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unread, Google Alerts, Google Alert - "Prop 65", Sep 18, Google "Prop 65" Daily update ⋅ September 18, 2018 NEWS Nexus Of Hype: Household Chemicals Cause Obesity, And the Undefined Gut Microbiota Is ... American Council on Science and Health There. Google Alerts	Google Alert - "Prop 65" - Google "Prop 65" Daily update ⋅ September 18, 2018 NEWS Nexus Of Hype: Household Chemicals Cause Obesity, And the Undefined Gut Microbiota Is ... American Council on Science and Health There	Sep 18
unread, Google Alerts, Google Alert - "Proposition 65", Sep 18, Google "Proposition 65" Daily update ⋅ September 18, 2018 NEWS Flawed Science at WHO Burdens Businesses in California - and Across the Country Economics21 A regulation known as Proposition 65. Google Alerts	Google Alert - "Proposition 65" - Google "Proposition 65" Daily update ⋅ September 18, 2018 NEWS Flawed Science at WHO Burdens Businesses in California - and Across the Country Economics21 A regulation known as Proposition 65	Sep 18
unread, The Washington Post, Evening Edition: Trump says he feels ‘badly’ for Kavanaugh: ‘This is not a man who deserves this’, Sep 18, The Fix: What happens to Brett Kavanaugh now? Here are 3 scenarios.; The Fix: Lindsey Graham's bizarre defense of not making Kavanaugh's friend testify The Washington Post Democracy Dies in. The Washington Post	Evening Edition: Trump says he feels ‘badly’ for Kavanaugh: ‘This is not a man who deserves this’ - The Fix: What happens to Brett Kavanaugh now? Here are 3 scenarios.; The Fix: Lindsey Graham's bizarre defense of not making Kavanaugh's friend testify The Washington Post Democracy Dies in	Sep 18
starred, Luda Kopelovich (2), Prop 65 conference sponsorship invoice, has attachments, Sep 18, Hi Lana, I wanted to follow up on my email and see if you had any questions about the vendor packet. We need to have it processed in our accounting department, so we can issue the check for the. Luda Kopelovich (2)	Prop 65 conference sponsorship invoice - Hi Lana, I wanted to follow up on my email and see if you had any questions about the vendor packet. We need to have it processed in our accounting department, so we can issue the check for the	Sep 18
starred, unread, Wendy Anne Crittend. (2), Program Attendees, has attachments, Sep 18, See attached. Feel free to clean up. Wendy Anne Crittenden 415.385.4364 wacrit@gmail.com www.wendycrittenden.com. Wendy Anne Crittend. (2)	Program Attendees - See attached. Feel free to clean up. Wendy Anne Crittenden 415.385.4364 wacrit@gmail.com www.wendycrittenden.com	Sep 18
starred, unread, Freddy .. Wendy (7), CA Env. Insider, Sep 18, Hi Freddy, I have removed Welner, Orlick, and Fleming as logins to your subscription. I have added LibDir@jmbm.com and MF@jmbm.com as logins. To login go to https://ceitoday.com/login and select ". Freddy .. Wendy (7)	Requests CA Env. Insider - Hi Freddy, I have removed Welner, Orlick, and Fleming as logins to your subscription. I have added LibDir@jmbm.com and MF@jmbm.com as logins. To login go to https://ceitoday.com/login and select "	Sep 18
unread, Wendy Anne Crittend., RJO logo fixed - it's in the DB folder, resaved with same name, Sep 18, Wendy Anne Crittenden 415.385.4364 wacrit@gmail.com www.wendycrittenden.com. Wendy Anne Crittend.	RJO logo fixed - it's in the DB folder, resaved with same name - Wendy Anne Crittenden 415.385.4364 wacrit@gmail.com www.wendycrittenden.com	Sep 18
unread, boarmanm, Wendy (2), Prop 65 Sponsorship Table, Sep 18, I just sent an email to all sponsors clarifying the shipping/receiving process. Wendy Crittenden Managing Editor wendy@prop65ch.com 415.385.4364 On Tue, Sep 18, 2018 at 11:13 AM <boarmanm@gtlaw.com. boarmanm, Wendy (2)	Prop 65 Sponsorship Table - I just sent an email to all sponsors clarifying the shipping/receiving process. Wendy Crittenden Managing Editor wendy@prop65ch.com 415.385.4364 On Tue, Sep 18, 2018 at 11:13 AM <boarmanm@gtlaw.com	Sep 18
unread, Beth .. Caryn .. (5), Cardless September?, Sep 18, Sept 28 works for me. (I thought we had checked our calendars last time ... did schedules change?) From: Lana Beckett <lanabbeckett@gmail.com> Sent: Monday, September 17, 2018 10:46:11 PM To:. Beth .. Caryn .. (5)	Cardless September? - Sept 28 works for me. (I thought we had checked our calendars last time ... did schedules change?) From: Lana Beckett <lanabbeckett@gmail.com> Sent: Monday, September 17, 2018 10:46:11 PM To:	Sep 18
starred, unread, Wendy Anne Crittend., Tom Lewandowski Bio, Sep 18, Can you take a look at Tom's bio - he sent me some overly done bio, can you glean enough info from it? He sent it to me this morning and asked if it would work for our purposes. Wendy Anne. Wendy Anne Crittend.	Tom Lewandowski Bio - Can you take a look at Tom's bio - he sent me some overly done bio, can you glean enough info from it? He sent it to me this morning and asked if it would work for our purposes. Wendy Anne	Sep 18
starred, unread, Lana, Wendy (2), program stuff, Sep 18, The logos you need are in the 2018 Sponsor Logos folder. You need to use the new Dentons logo in there that has the Chinese characters, and the EGC_name logo for EGC. Pam converted CMBG3's to a pdf. Lana, Wendy (2)	program stuff - The logos you need are in the 2018 Sponsor Logos folder. You need to use the new Dentons logo in there that has the Chinese characters, and the EGC_name logo for EGC. Pam converted CMBG3's to a pdf	Sep 18
starred, Wendy, Celina (3), Prop. 65 Conference Attendees, Sep 18, Absolutely. I will have Lana refund the $1200 and I have removed Josh and added Randy. See you at the conference! Wendy Wendy Crittenden Managing Editor wendy@prop65ch.com 415.385.4364 On Tue, Sep 18,. Wendy, Celina (3)	Prop. 65 Conference Attendees - Absolutely. I will have Lana refund the $1200 and I have removed Josh and added Randy. See you at the conference! Wendy Wendy Crittenden Managing Editor wendy@prop65ch.com 415.385.4364 On Tue, Sep 18,	Sep 18
unread, Wendy Anne Crittend. (2), Premier Logos, Sep 18, Hi Pam, Can you send over the logos you have for CMBG3, Crowell & Moring, EGC, and Dentons. Lana needs them for the program. Thanks! Wendy Wendy Anne Crittenden 415.385.4364 wacrit@gmail.com www.. Wendy Anne Crittend. (2)	Premier Logos - Hi Pam, Can you send over the logos you have for CMBG3, Crowell & Moring, EGC, and Dentons. Lana needs them for the program. Thanks! Wendy Wendy Anne Crittenden 415.385.4364 wacrit@gmail.com www.	Sep 18

starred, Carol@OEHHA .. Lana (12), New case, has attachments, Sep 14, vikkigidg@gmail.com> wrote: Ok. I'll enter it without a number as a new case. Let's talk about it at some point. Carol@OEHHA .. Lana (12)	News Stories New case - vikkigidg@gmail.com> wrote: Ok. I'll enter it without a number as a new case. Let's talk about it at some point	Sep 14
Lana Beckett, 9-10-18 cases, has attachments, Sep 10, Next group.... see ya in a couple of weeks..... Lana Beckett, Publisher Prop. 65 ClearinghouseC*. Lana Beckett	9-10-18 cases - Next group.... see ya in a couple of weeks..... Lana Beckett, Publisher Prop. 65 ClearinghouseC*	Sep 10
Lana, Vikki (2), 8-23-18, has attachments, Sep 1, Hey Lana, These are done. A related case to DiPirro v. Ace is DiPirro v. Angelo Bros. but we don'. Lana, Vikki (2)	Litigation 8-23-18 - Hey Lana, These are done. A related case to DiPirro v. Ace is DiPirro v. Angelo Bros. but we don'	Sep 1
unread, Vikki, Wendy (2), Hope's work, Aug 30, vikkigidg@gmail.com> wrote: Hey gals, Hope is starting to add settlements. She is a quick study but I am still checking. Vikki, Wendy (2)	Inbox Hope's work - vikkigidg@gmail.com> wrote: Hey gals, Hope is starting to add settlements. She is a quick study but I am still checking	Aug 30
Lana, Vikki (4), 8-7-18 case docs, has attachments, Aug 23, vikkigidg@gmail.com> wrote: Hey Lana, I am leaving for a week to Idaho (I no Ho!) on Friday. How soon do you want these entered. Lana, Vikki (4)	Litigation 8-7-18 case docs - vikkigidg@gmail.com> wrote: Hey Lana, I am leaving for a week to Idaho (I no Ho!) on Friday. How soon do you want these entered	Aug 23
Lana, Vikki (2), 7-22-18, has attachments, Aug 6, Done! On Sun, Jul 22, 2018 at 11:41 AM, Lana Beckett wrote: > > > Lana Beckett, Publisher. Lana, Vikki (2)	Litigation 7-22-18 - Done! On Sun, Jul 22, 2018 at 11:41 AM, Lana Beckett wrote: > > > Lana Beckett, Publisher	Aug 6
Lana, Vikki (2), need to also post these docs, has attachments, Aug 6, Done! On Thu, Aug 2, 2018 at 10:05 PM, Lana Beckett wrote: > DiPirro v. Bondo from 2003-2007 may. Lana, Vikki (2)	Litigation need to also post these docs - Done! On Thu, Aug 2, 2018 at 10:05 PM, Lana Beckett wrote: > DiPirro v. Bondo from 2003-2007 may	Aug 6
starred, Lana .. Deli., Vikki (9), Appeal court case docs in Post Foods, has attachments, Aug 3, vikkigidg@gmail.com> wrote: What was the original file date for the appeal? Thanks! On Thu, Aug 2, 2018 at 2:39 PM, Lana. Lana .. Deli., Vikki (9)	Litigation Appeal court case docs in Post Foods - vikkigidg@gmail.com> wrote: What was the original file date for the appeal? Thanks! On Thu, Aug 2, 2018 at 2:39 PM, Lana	Aug 3
starred, Lana, Vikki (2), Sowinski v. Post, has attachments, Aug 2, Ok boss! On Wed, Aug 1, 2018 at 11:09 PM, Lana Beckett wrote: > The appeal court just ruled on. Lana, Vikki (2)	Litigation Sowinski v. Post - Ok boss! On Wed, Aug 1, 2018 at 11:09 PM, Lana Beckett wrote: > The appeal court just ruled on	Aug 2
Lana Beckett, fifth and last, Aug 2, 1695088221.pdf Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street, Suite 1. Lana Beckett	fifth and last - 1695088221.pdf Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street, Suite 1	Aug 2
Lana Beckett, fourth, Aug 2, 1682734218.pdf Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street, Suite 1. Lana Beckett	fourth - 1682734218.pdf Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street, Suite 1	Aug 2
Lana Beckett, third group, Aug 2, 1682734073.pdf Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street, Suite 1. Lana Beckett	third group - 1682734073.pdf Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street, Suite 1	Aug 2
Lana Beckett, second group, has attachments, Aug 1, Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street, Suite 1 San Francisco,. Lana Beckett	second group - Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street, Suite 1 San Francisco,	Aug 1
Vikki, Lana (2), Vikki Invoice, has attachments, Jul 31, vikkigidg@gmail.com> wrote: Hey Lana, I will definitely be coming up for the weekend before the conference (and the. Vikki, Lana (2)	Independent Contractors Vikki Invoice - vikkigidg@gmail.com> wrote: Hey Lana, I will definitely be coming up for the weekend before the conference (and the	Jul 31
starred, Lana, Vikki (5), 7-5-18, has attachments, Jul 22, vikkigidg@gmail.com> wrote: Whew, finally finished the batch. The Schwarzenegger v. Sierra Club appeal doc was giving. Lana, Vikki (5)	Litigation 7-5-18 - vikkigidg@gmail.com> wrote: Whew, finally finished the batch. The Schwarzenegger v. Sierra Club appeal doc was giving	Jul 22
Lana, Vikki (2), 7-2-18 group, has attachments, Jul 5, Done! All were previously entered. I sat down with Hope again on Tues. She is going to start entering. Lana, Vikki (2)	Litigation 7-2-18 group - Done! All were previously entered. I sat down with Hope again on Tues. She is going to start entering	Jul 5
Lana, Vikki (2), 6/27/18 bunch, has attachments, Jul 2, Done! On Wed, Jun 27, 2018 at 9:22 PM, Lana Beckett wrote: > Okay Speedy! here is the next bunch!. Lana, Vikki (2)	Litigation 6/27/18 bunch - Done! On Wed, Jun 27, 2018 at 9:22 PM, Lana Beckett wrote: > Okay Speedy! here is the next bunch!	Jul 2
Lana, Vikki (4), 6/26/18 case docs, has attachments, Jun 27, vikkigidg@gmail.com> wrote: Hope was happy with the deal! i started showing Hope the website. She is entering some notices. Lana, Vikki (4)	Litigation 6/26/18 case docs - vikkigidg@gmail.com> wrote: Hope was happy with the deal! i started showing Hope the website. She is entering some notices	Jun 27
Vikki, Lana (3), Re: 6-23-18 case docs, has attachments, Jun 27, vikkigidg@gmail.com> wrote: I can't find it. I was hoping you had some insider info. On Sun, Jun 24, 2018 at 7:24 PM. Vikki, Lana (3)	Litigation Re: 6-23-18 case docs - vikkigidg@gmail.com> wrote: I can't find it. I was hoping you had some insider info. On Sun, Jun 24, 2018 at 7:24 PM	Jun 27
Lana, Vikki (4), 6/24/18 bunch, has attachments, Jun 26, vikkigidg@gmail.com> wrote: In this batch, it looks like only 3 docs that haven't been entered. On Sun, Jun 24, 2018. Lana, Vikki (4)	Litigation 6/24/18 bunch - vikkigidg@gmail.com> wrote: In this batch, it looks like only 3 docs that haven't been entered. On Sun, Jun 24, 2018	Jun 26
Lana, Vikki (4), backlog case docs, has attachments, Jun 23, All 11 docs checked and entered. On Thu, Jun 21, 2018 at 2:32 PM, Lana Beckett wrote: > Hi Gidg:. Lana, Vikki (4)	Litigation backlog case docs - All 11 docs checked and entered. On Thu, Jun 21, 2018 at 2:32 PM, Lana Beckett wrote: > Hi Gidg:	Jun 23
Fiona, Lana, Vikki (4), UPDATED AND EDITED - USE THIS VERSION July 1, 2018 Stories Part One, has attachments, Jun 22, Done! On Fri, Jun 22, 2018 at 12:02 AM, Lana Beckett wrote: > 2 more case docs for the Starbucks. Fiona, Lana, Vikki (4)	Litigation UPDATED AND EDITED - USE THIS VERSION July 1, 2018 Stories Part One - Done! On Fri, Jun 22, 2018 at 12:02 AM, Lana Beckett wrote: > 2 more case docs for the Starbucks	Jun 22
Lana, Vikki (2), do the attached cases first, has attachments, Jun 21, You got it boss! On Thu, Jun 21, 2018 at 6:18 PM, Lana Beckett wrote: > Coffee and glyphosate are. Lana, Vikki (2)	Litigation do the attached cases first - You got it boss! On Thu, Jun 21, 2018 at 6:18 PM, Lana Beckett wrote: > Coffee and glyphosate are	Jun 21
starred, Fiona, Roger, Lana (8), Fwd: Activity in Case 2:17-cv-02401-WBS-EFB National Association of Wheat Growers et al v. Zeise et al Memorandum, Opinion & Order., has attachments, Jun 20, more case docs to upload... Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine. Fiona, Roger, Lana (8)	News Stories Fwd: Activity in Case 2:17-cv-02401-WBS-EFB National Association of Wheat Growers et al v. Zeise et al Memorandum, Opinion & Order. - more case docs to upload... Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine	Jun 20
Lana, Vikki, Wendy (5), more case docs, has attachments, Jun 18, vikkigidg@gmail.com> Date: Mon, Jun 18, 2018 at 3:51 PM Subject: Re: more case docs To: Lana Beckett <lana@prop65ch. Lana, Vikki, Wendy (5)	Litigation News Stories more case docs - vikkigidg@gmail.com> Date: Mon, Jun 18, 2018 at 3:51 PM Subject: Re: more case docs To: Lana Beckett <lana@prop65ch	Jun 18
Lana Beckett, please let Wendy know when you post the case docs., Jun 18, Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street, Suite 1 San Francisco,. Lana Beckett	please let Wendy know when you post the case docs. - Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street, Suite 1 San Francisco,	Jun 18
Vikki Paulus (2), Mailing Address, Apr 13, vikkigidg@gmail.com> Date: Wed, Jun 28, 2017 at 4:03 PM Subject: Mailing Address To: Lana Becket <lana@prop65ch. Vikki Paulus (2)	Independent Contractors Mailing Address - vikkigidg@gmail.com> Date: Wed, Jun 28, 2017 at 4:03 PM Subject: Mailing Address To: Lana Becket <lana@prop65ch	Apr 13
starred, Vikki, Lana (2), Yo Bitch!, Mar 13, vikkigidg@gmail.com> wrote: Hey Lana, How's it goin? Just starting the tax preparation process. Did you send me. Vikki, Lana (2)	Independent Contractors Yo Bitch! - vikkigidg@gmail.com> wrote: Hey Lana, How's it goin? Just starting the tax preparation process. Did you send me	Mar 13
Vikki, me (2), Thank you!, 12/28/17, vikkigidg@gmail.com> wrote: Hey Lana, Got your package the other night. Thank you for the beautifully wrapped gifts. Vikki, me (2)	Independent Contractors Thank you! - vikkigidg@gmail.com> wrote: Hey Lana, Got your package the other night. Thank you for the beautifully wrapped gifts	12/28/17
Vikki Paulus, got my check!, 12/7/17, Thank you Lana!. Vikki Paulus	Independent Contractors got my check! - Thank you Lana!	12/7/17
Wendy .. Lana, Vikki (10), GIDJ NEEDS A PAYCHECK, 11/13/17, That's perfect Lana. I can't wait to hear about Bali! On Sat, Nov 11, 2017 at 5:26 PM, Lana. Wendy .. Lana, Vikki (10)	Independent Contractors GIDJ NEEDS A PAYCHECK - That's perfect Lana. I can't wait to hear about Bali! On Sat, Nov 11, 2017 at 5:26 PM, Lana	11/13/17
Vikki Paulus, Vikki's hours, 11/5/17, Hey Lana, I let unemployment know that I was hired by you as of Oct. 30. I put down that I worked 30. Vikki Paulus	Independent Contractors Vikki's hours - Hey Lana, I let unemployment know that I was hired by you as of Oct. 30. I put down that I worked 30	11/5/17
Lana, Vikki (3), I have your shoes, 10/25/17, vikkigidg@gmail.com> wrote: Hey Ms. Lana, Don't need the shoes. Add them to the doggie toy basket. They started. Lana, Vikki (3)	Independent Contractors I have your shoes - vikkigidg@gmail.com> wrote: Hey Ms. Lana, Don't need the shoes. Add them to the doggie toy basket. They started	10/25/17
starred, Wendy .. Lana, Vikki (6), Go ahead and invite The Gidge to work the conference, 9/20/17, vikkigidg@gmail.com> Hi Gidg: HR (Wendy) has just given me the green light to invite you up to work the Prop. 65 Conference. Wendy .. Lana, Vikki (6)	zOld Co…/Conference 2017 zOld Conferences/…/venue Go ahead and invite The Gidge to work the conference - vikkigidg@gmail.com> Hi Gidg: HR (Wendy) has just given me the green light to invite you up to work the Prop. 65 Conference	9/20/17
starred, unread, Vikki Paulus, Cheng v. SKF USA, 8/11/17, This case has 2 Complaints/2 docket numbers: one in Alameda and one in San Diego. Why? Notice: 2016-. Vikki Paulus	Litigation Cheng v. SKF USA - This case has 2 Complaints/2 docket numbers: one in Alameda and one in San Diego. Why? Notice: 2016-	8/11/17
starred, unread, Vikki Paulus, Cases to look at, 8/11/17, Look up CGC16554012 AND CGC16554276 Love ya!. Vikki Paulus	Litigation Cases to look at - Look up CGC16554012 AND CGC16554276 Love ya!	8/11/17
Vikki, me (2), Houghton Lake, has attachments, 7/19/17, vikkigidg@gmail.com> wrote: Hey Lana, I am usually at the library working (haha) but when I am not, I am hanging around. Vikki, me (2)	Personal Houghton Lake - vikkigidg@gmail.com> wrote: Hey Lana, I am usually at the library working (haha) but when I am not, I am hanging around	7/19/17
Vikki, me (5), July in Michigan, 7/13/17, vikkigidg@gmail.com> wrote: Check arrived but prob won't deposit for 2 more weeks as my bank is not anywhere in sight. Vikki, me (5)	Independent Contractors July in Michigan - vikkigidg@gmail.com> wrote: Check arrived but prob won't deposit for 2 more weeks as my bank is not anywhere in sight	7/13/17
Vikki Paulus, June Timesheet, has attachments, 6/28/17, Hey Lana, Attached is my timesheet for June. I included 2 hours for tomorrow/Friday for an even 40. Vikki Paulus	Independent Contractors June Timesheet - Hey Lana, Attached is my timesheet for June. I included 2 hours for tomorrow/Friday for an even 40	6/28/17
Lana, Vikki (2), Last group of GCM doc, has attachments, 6/28/17, Cool. I'll get on this today! On Tue, Jun 27, 2017 at 6:33 PM, Lana Beckett wrote: > here you. Lana, Vikki (2)	Litigation Last group of GCM doc - Cool. I'll get on this today! On Tue, Jun 27, 2017 at 6:33 PM, Lana Beckett wrote: > here you	6/28/17
Lana Beckett, more GCM docs, has attachments, 6/27/17, one more group of GCM docs after this... Lana Beckett, Publisher Prop. 65 ClearinghouseC*EI Today. Lana Beckett	more GCM docs - one more group of GCM docs after this... Lana Beckett, Publisher Prop. 65 ClearinghouseC*EI Today	6/27/17
Lana Beckett, more case docs, has attachments, 6/27/17, Hi Gidg: Here are some more from Global Community Monitor v. Lumber Liquidators. this is the first of. Lana Beckett	more case docs - Hi Gidg: Here are some more from Global Community Monitor v. Lumber Liquidators. this is the first of	6/27/17
Lana Beckett, case docs to post, has attachments, 6/27/17, Hi Gidg: I know you do not have enough to do.... I have these case docs that need to be posted on. Lana Beckett	case docs to post - Hi Gidg: I know you do not have enough to do.... I have these case docs that need to be posted on	6/27/17
Vikki Paulus, Jetblue receipt, 6/7/17, Hey Lana, I requested a proper receipt that Jetblue will send to you via email. Had a great time with. Vikki Paulus	Independent Contractors Jetblue receipt - Hey Lana, I requested a proper receipt that Jetblue will send to you via email. Had a great time with	6/7/17
Lana Beckett, swhop, 6/4/17, https://www.buykud.com/ Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street. Lana Beckett	swhop - https://www.buykud.com/ Lana Beckett, Publisher Prop. 65 ClearinghouseCEI Today 737 Pine Street	6/4/17
starred, Lana, Vikki, Caryn (3), rubbyscrubby, 5/30/17, Yes! On Tue, May 30, 2017 at 2:11 PM, Lana Beckett wrote: > Since Gidg was not coming in until. Lana, Vikki, Caryn (3)	Personal rubbyscrubby - Yes! On Tue, May 30, 2017 at 2:11 PM, Lana Beckett wrote: > Since Gidg was not coming in until	5/30/17
Lana Beckett, call me, 5/30/17, Hey Girlfriend: Call me. I did not mail your check yet. Was waiting to here if you wanted to get it. Lana Beckett	call me - Hey Girlfriend: Call me. I did not mail your check yet. Was waiting to here if you wanted to get it	5/30/17
Vikki, me (2), VikkiGidg Timesheet Alert, has attachments, 5/25/17, vikkigidg@gmail.com> wrote: Hey Lanarama, Hope all is well in SF. I'm gearing up to go on a camping trip with the Boy. Vikki, me (2)	Independent Contractors VikkiGidg Timesheet Alert - vikkigidg@gmail.com> wrote: Hey Lanarama, Hope all is well in SF. I'm gearing up to go on a camping trip with the Boy	5/25/17
Vikki Paulus, Gidget flight, 5/5/17, Hey Lana, I'm not finding anything good for next weekend flight. Do you want me to ship your. Vikki Paulus	Independent Contractors Gidget flight - Hey Lana, I'm not finding anything good for next weekend flight. Do you want me to ship your	5/5/17
Vikki, Lana (3), Timesheet, has attachments, 4/26/17, vikkigidg@gmail.com> wrote: Hey Lana, Attached is my timesheet. Plugging along. March 2016 was a busy month for notices. Vikki, Lana (3)	Independent Contractors Timesheet - vikkigidg@gmail.com> wrote: Hey Lana, Attached is my timesheet. Plugging along. March 2016 was a busy month for notices	4/26/17

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