| Here is a sample declaration text.
If you have questions, contact: Jane Cavanaugh <janecava@earthlink.com>, Jamyrson Pittori <jamyroson@cruzio.com> or Christopher Dort,<cbd@bvsllp>. This form will probably not print out well directly from this webpage, it's too long for a single sheet of paper. Try copying and pasting it into a regular text file in your own computer, and format to your satisfaction and print it out from there. Christopher B. Dort (Bar No. 196832 )
Superior Court Of The State Of California - County Of Santa Cruz Jane Cavanaugh, Et Al. (A.K.A. Woodland Preservation Group), Plaintiffs,
Case No. _________
_________________Declaration _________________ I, _________________________________________ , declare under penalty of perjury that the following is true and correct. 1. I am a resident of the real property located at
2. Pacific Gas & Electric Company (PG&E) is engaged in "Vegetation Management" activities near my residence. 3. During these activities, I have personally observed PG&E and/or their agents, employees, representatives and contractors clear cutting large areas of property, including the cutting and removal of healthy trees, bulldozing and damaging foliage, and destroying endangered plants and their habitat. 4. I believe that these actions have resulted in excessive and obvious property damage outside the scope of any easement or right of way that PG&E has on the affected property. 5. These damages will include, but are not limited to, an increased risk of unnatural mud flows, unnatural drainage of water, possibility of damage to remaining foliage and trees due to unnatural "windtunnel" effects, unnatural vegetation growth patterns, and will allow the invasion of non-native vegetation. 6. These effects have adversely affected the value of real property where PG&E has performed "Vegetation Management". 7. I am aware of PG&E, and their agents or representatives, employees and contractors, misrepresenting the scope of their right to engage in "Vegetation Management" as well as their future intentions to property owners. 8. I have received notice from PG&E, and/or PG&E and their agents or representatives, employees and contractors have made it clear through their actions that their continued practice of "Vegetation Management" will proceeds on or near my residence. I believe and that it will cause irreparable damage to my property in the immediate future including loss of market value, and loss of aesthetic beauty and other effects that will adversely affect the use and enjoyment of my property. 9. I support the plaintiff’s petition for a Preliminary Injunction to stop PG&E, and their agents or representatives, employees and contractors from continuing their destructive activities. 10. I respectfully request that the Preliminary Injunction be granted in order to prevent further damage and destruction. DATED: ______________________, 1999 Respectfully submitted, By: _____________________________________________________________
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