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                IN THE COURT OF GENERAL SESSIONS
                 HAMILTON COUNTY TENNESSEE

__________________________     ;
CITY OF CHATTANOOGA            ;        
                               ;
                Plaintif,      ;        Docket No. Dogs6397
                               ;
V                              ;
                               ;
OLIVER PLUMBING COMPANY,       ;
                               ;
                Defendant,     ;
_________________________      ;


                             Counterclaim

      Comes now the Defendant Ernest A. Oliver, d/b/a Oliver Plumbing,
and assuming the role of Counterclaimant (thereinafter
"Defendant/Counterclaimant") pursuant to Rule 13.01, Tennessee
Rules of Civil Procedure, assetts the following Counterclaim
against the City of Chattanooga (hereinafter "City").
1. Oliver Plumbing is a sole proprietorship owned and
operated by Ernest A. Oliver ("Oliver") doing the business of small
plumbing jobs in the Chattanooga Area, Due to his whistle blowing
against an illegal hazardous waste dumping operation in the
Chattanooga Area, Oliver has lost two (2) scientific positions in
Chattanooga and was forced to get into the plumbing business in 1994
in order to make a living.




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