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I out below, are in violation of the law and public policy of the State of California. Unless 2 enjoined and restrained by an order of this court, the defendants will continue to engage in and 3 continue to retain the means to engage in the unlawful actions and practices set out below, 4 4. Whenever in this complaint reference is made to any act of defendants, such allegation 5 shall be deemed to mean that defendants and its officers,agents, employees, or representatives, 6 did or authorized acts while actively engaged in the management, direction or control of the 7 affairs of said defendants, and while acting within the course and scope of their duties. 8 5. Defendants DENNIS ROMERO and SHERRY ROMERO at all times relevant herein 9 were the record owners of the property located at 2523 East Scotts Street, Stockton,CA,San 10 Soaquin County Recorder's Office APN # 155-452-08. 11 6. Defendant DAVID FISCH is now and at all times relevant herein was engaged in the 12 business of providing general contracting,consulting and environmental remediation services, 13 located at 1040 W. Kettleman Lane, l B-156,Lodi,CA,and at various locations throughout the 14 county of San Joaquin and elsewhere in the State of California. 15 7. Defendant FISCH ENVIRONMENTAL CONSTRUCTION, an entity of unknown 16 type of organization, is now and at all times relevant herein was engaged in the business of I7 providing general contracting,consulting and environmental remediation services, located at 18 1040 W. Kettleman Lane, 1B-156,Lodi,CA,and at various locations throughout the county of 19 San Joaquin and elsewhere in the State of California. 20 8. Defendants DOES 1 through 20 are connected and responsible for the acts complained 21 of below. Their real names are unknown at this time, and the People will amend this complaint 22 at a later date when the true identities of DOES I through 20 are discovered. 23 FIRST CAUSE OF ACTION 24 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. (UNDERGROUND STORAGE OF 25 HAZARDOUS MATERIALS) 26 9. Plaintiff is informed and believes and based on such information and belief alleges that 27 beginning at an exact date that is unknown to plaintiff,but within five (5) years prior to the filing 28 of this complaint(CCP §338.1),defendants DENNIS ROMERO and SHERRY ROMERO have 2