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1 representatives, did or authorized acts while actively engaged in the management, direction, or <br /> 2 control of the affairs of said defendants, and while acting within the course and scope of their <br /> 3 duties. <br /> 4 <br /> 5 FIRST CAUSE OF ACTION <br /> 6 VIOLATIONS OF HEALTH AND SAFETY CODE <br /> 7 SECTION 25280 ET SEQ. (UNDERGROUND STORAGE OF <br /> 8 HAZARDOUS MATERIALS) <br /> 9 9. Plaintiff is informed and believes and based on such information and belief <br /> 10 alleges that beginning at an exact date that is unknown to plaintiff, but within five (5)years prior <br /> 1 I to the filing of this complaint(CCP §338.1), defendants engaged in violated Health and Safety <br /> 12 Code Chapter 6.7, including but not limited to: <br /> 13 a. Violation of Health and Safety Code §25284(a), failed to obtain a permit <br /> 14 for four underground storage tanks; <br /> 15 b. Violation of Health and Safety Code §25292(a), failed to outfit four <br /> 16 underground tank systems with a monitoring system on or before July 1, 1985; <br /> 17 C. Violation of Health and Safety Code §25292(d), failed to replace or <br /> 18 upgrade four underground storage tanks on or before December 22, 1998; <br /> 19 d. Violation of Health and Safety Code §25298(x), illegally abandoned four <br /> 20 underground storage tank systems; <br /> 21 <br /> 22 SECOND CAUSE OF ACTION <br /> 23 VIOLATION OF BUSINESS AND PROFESSIONS CODE <br /> 24 SECTIONS 17200 ET SEQ. (UNLAWFUL AND/OR <br /> 25 UNFAIR COMPETITION) <br /> 26 10. Paragraphs 1 through 9d, above are incorporated herein by reference. Plaintiff is <br /> 27 informed and believes and based on such information and belief alleges that beginning at an <br /> 28 <br /> 3 <br />