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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />throughout California, including one or more Covered Facility in each of the counties represented <br />by the Local Prosecutors herein. <br />7. Target is, and at all times relevant to the claims in this Complaint was, legally <br />responsible for compliance with -the provisions of the California Health and Safety Code, <br />including, but not limited to, Chapters 6.5- and 6.95 of Division 20, and the corresponding <br />implementing regulations, in connection with Target's ownership and/or operation of the Covered <br />Facilities. <br />8. Target is a "person" as defined in California Health and Safety Code section 25118. <br />Target is a "business" as defined in California Health and Safety Code section 25501, subdivision <br />B] <br />9. In this Complaint when reference is made to any act or omission of Target, such <br />allegations shall include the acts and omissions of owners, officers, directors, agents, employees, <br />contractors, vendors, affiliates, and/or representatives of Target while acting within the course . <br />and scope of their employment or agency on behalf of Target. <br />10. The identities of DOES 1-25 are unknown to 'Plaintiff at this time. At such time as <br />the identities of DOE defendants become known, Plaintiff will amend this Complaint ' <br />accordingly. DOES 1-25 are, and at all times relevant to the claims in this Complaint were, <br />legally responsible for compliance with the provisions of -the California Health and Safety Gbde, <br />including, but not limited to, Chapters 6.5 and 6.95 of Division 20, and the corresponding <br />implementing regulations, in connection with the ownership and/or operation of the Covered <br />Facilities. Target and*DOES 1-25 are collectively referred to herein as "Defendants." <br />11. At all times relevant hereto, DOES i-10 were in a position of responsibility allowing <br />them to influence corporate policies, or activities with respect to Target's compliance with <br />California environmental laws and regulations at the Covered Facilities, and had, by reason of <br />their position in the corporation, responsibility and authority either to prevent in the first instance, <br />or promptly to correct, the violations complained of herein, but failed to do so. In addition to any <br />direct personal liability of these individuals, DOES 1-10 also are personally liable under the <br />I <br />First Amended Complaint for Preliminary and Permanent Injunction, Civil Penalties and Other Equitable Relief <br />Case No. RG09457686 <br />