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1 14. Defendant DOES ONE through TWENTY are connected and responsible for the acts <br /> 2 complained of below. Their real names are unknown at this time, and the People will amend this <br /> 3 complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br /> 4 15. Whenever in this Complaint reference is made to any act of Defendants,such allegation <br /> 5 shall be deemed to mean that Defendants and their officers, agents,employees, or representatives,did <br /> 6 or authorized acts while actively engaged in the management, direction,or control of the affairs of <br /> 7 said Defendants,and while acting within the course and scope of their duties. <br /> 8 FIRST CAUSE OF ACTION <br /> 9 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. <br /> 10 (HAZARDOUS WASTE CONTROL ACT) <br /> 11 16. Plaintiff is informed and believes and based on such information and belief alleges that <br /> 12 beginning at an exact date that is unknown to Plaintiff, but within five(5)years prior to the filing of <br /> 13 this Complaint(CCP §338.1),Defendants engaged in acts in violation of Health and Safety Code <br /> 14 §25100 et seq.,including by not limited to the following: <br /> 15 a. Treated, stored, disposed of,transported or offered to transport hazardous waste <br /> 16 without having an Identification Number,in violation of California Code of Regulations,title 22 <br /> 17 section 66262.12(a); <br /> 18 b. Stored hazardous waste on site longer than one hundred eighty(180)days,in <br /> 19 violation of California Code of Regulations,title 22 section 66262.34(d); <br /> 20 c. Failed to maintain modified emergency coordinator information,in violation of <br /> 21 California Code of Regulations,title 22 section 66262.34(d)(2); <br /> 22 d. Failed to label or mark containers used for onsite accumulation of hazardous waste, <br /> 23 in violation of California Code of Regulations,title 22 section 66262.34(f); <br /> 24 e. Failed to retain copies of signed manifest for at least three(3)years,in violation of <br /> 25 California Code of Regulations,title 22 section 66262.40(a); <br /> 26 f. Failed to maintain and operate facility to minimize the possibility of a fire, <br /> 27 explosion,or any unplanned sudden or non-sudden release of hazardous waste, in violation of <br /> 28 California Code of Regulations,title 22 section 66265.31;and <br /> 4 <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />