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2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <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 />been carried out within said San Joaquin County and elsewhere throughout the State of California. <br />The alleged actions of the Defendants and each of them, jointly and separately, as set out below, are <br />in violation of the law and public policy of the State of California. Unless enjoined and restrained by <br />an order of this court, the Defendants will continue to retain the means to engage in unlawful action <br />and practices and courses of conduct set out below. <br />DEFENDANTS <br />4. Defendant VILLAGE WEST MARINA INVESTORS, a California Limited Partnership, a <br />business of unknown type of organization, is, and at all times relevant herein was, engaged in the <br />business of MARINA AND BOAT STORAGE, located at 6649 EMBARCADERO DRIVE, <br />STOCKTON, CALIFORNIA. <br />5. Defendant DOES ONE through FIFTY are connected and responsible for the acts <br />complained of below. Their real names are unknown at this time, and the People will amend this <br />complaint at a later date when the true identities of DOES ONE through FIFTY are discovered. <br />6. Whenever in this Complaint reference is made to any act of Defendants, such allegation <br />shall be deemed to mean that Defendants and their officers, agents, employees, or representatives, <br />did or authorized acts while actively engaged in the management, direction, or control of the affairs <br />of said Defendants, and while acting within the course and scope of their duties. <br />FIRST CAUSE OF ACTION <br />VIOLATION OF HEALTH. AND SAFETY CODE SECTION 25100 ET SEQ. <br />(HAZARDOUS WASTE CONTROL ACT) <br />7. Paragraphs 1 through 6, above are incorporated herein by reference. Plaintiff is informed <br />and believes and based on such irnformation and belief alleges that beginning at an exact date that is <br />unknown to Plaintiff, but within five (5) years prior to the filing of this Complaint (CCP §338.1), <br />Defendants engaged in acts in violation of Health and Safety Code §25100 et seq., including by not <br />limited to the following: <br />a. Failed to maintain and operate facility to minimize the possibility of a fire, <br />explosion, or any unplanned sudden or non -sudden release of hazardous waste, in violation of <br />California Code of Regulations, title 22 section 66265.31; <br />SECOND AIMENDED VERIFIED COMPLAINT FOR INJUNCYION, CIVIL PENALTIES, AND OTHER RELIEF <br />