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such defendants by such fictitious names. Plaintiff will amend <br /> 1 <br /> 2 this complaint to show their true names and capacities when <br /> 3 ascertained. Plaintiff is informed and believes and thereupon <br /> 4 alleges that each of the defendants designated herein as a Doe <br /> 5 is legally responsible in some manner for the events and <br /> 8 happenings alleged in this complaint. <br /> 7 . When, in this complaint, reference is made to any act <br /> 7 ' <br /> of the defendants, such allegations shall be deemed to mean that <br /> 8 <br /> 9 the officers, directors, agents, employees, or representatives <br /> of said defendants did, or authorized, such acts, or recklessly <br /> 10 <br /> 11 and carelessly failed and omitted. to adequately or properly <br /> 12 supervise, control or direct their employees and agents while <br /> 13 engaged in the management, direction, operation, or control of <br /> 14 the affairs of said business organization and did so while <br /> 15 acting within the course and scope of their employment or <br /> 18 agency. <br /> 17 INTRODUCTION <br /> 18 In 1983 , the Legislature enacted Health and Safety Code <br /> 19 Sections 25280 et seq. regarding regulation of underground tanks <br /> 20 used to store hazardous substances, such as gasoline tanks. The <br /> 21 owners and operators of such tanks were required to test the <br /> 22 integrity of their tanks to ensure that leakage of hazardous <br /> 23 substances was not occurring. If leakage was detected, the law <br /> 24 required that the tanks be excavated and removed. In addition, <br /> 25 the removal of any underground tank which had contained <br /> 28 hazardous substances required that the soil under the tank be <br /> 27 tested to determine if soil contamination was present. If <br /> 28 <br /> 3 <br />