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I violation of the law and public policy of the State of California. Unless enjoined and restrained by <br /> 2 an order of this court, the defendants will continue to retain the means to engage in unlawful action <br /> 3 and practices and courses of conduct set out below. <br /> 4 DEFENDANTS <br /> 5 4. Whenever in this complaint reference is made to any act of defendants, such allegation <br /> 6 shall be deemed to mean that defendants and its officers, agents, employees, or representatives, did <br /> 7 or authorized acts while actively engaged in the management, direction, or control of the affairs of <br /> 8 said defendant, and while acting within the course and scope of their duties. <br /> 9 5. Defendant JUAN'S AUTO REPAIR, a business of unknown type of organization. is, and <br /> 10 at all times relevant herein was, engaged in the business of AUTO REPAIR. located at 1145 SOUTH <br /> 11 AURORA ST., STOCKTON, CALIFORNIA. <br /> 12 6. Defendant JUAN O. MORGA is, and at all times relevant herein was, engaged in the <br /> 13 business of AUTO REPAIR, located at 1145 SOUTH AURORA ST., STOCKTON, CALIFORNIA. <br /> 14 7. Defendant DOES I through 10 are connected and responsible for the acts complained of <br /> 15 below. Their real names are unknown at this time, and the People will amend this complaint at a <br /> 16 later date when the true identities of DOES 1 through 10 are discovered. <br /> 17 <br /> 18 FIRST CAUSE OF ACTION <br /> 19 VIOLATION OF HEALTH AND SAFETY CODE <br /> 20 CHAPTER 6.95 (EMERGENCY BUSINESS RESPONSE PLANS) <br /> 21 8. Plaintiff is informed and believes and based upon such information and belief alleges that <br /> 22 beginning at an exact date that is unknown to plaintiff, but within four(4) year prior to the filing of <br /> 23 this complaint, defendants engaged in acts in violation of Health and Safety Code Chapter 6.95. <br /> 24 9. The violations of Health and Safety Code Chapter 6.95 include but are not limited to the <br /> 25 following: <br /> 26 9a. Violation of Health and Safety Code § 25503.5 by being a business which handles <br /> 27 hazardous materials of more than 55 gallons. 500 pounds or 200 cubic feet including but not limited <br /> 28 <br />