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I RETAIL SALES,located at 515 W. 11 Tx STREET,TRACY, CALIFORNIA. <br /> 2 9. Defendant DOES ONE through TWENTY are connected and responsible for the acts <br /> 3 complained of below. Their real names are unknown at this time, and the People will amend this <br /> 4 complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br /> 5 10. Whenever in this complaint reference is made to any act of defendants,such <br /> 6 allegation shall be deemed to mean that defendants and their officers, agents, employees, or <br /> 7 representatives, did or authorized acts while actively engaged in the management, direction, or <br /> 8 control of the affairs of said defendant, and while acting within the course and scope of their duties. <br /> 9 11. All defendants at all times acted as agents of one another. With regard to the conduct <br /> 10 and omissions alleged in this Complaint, each of the defendants ratified the actions of the other <br /> 11 defendants. <br /> 12 FIRST CAUSE OF ACTION <br /> 13 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br /> 14 (UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br /> 15 12. Plaintiff is informed and believes and based upon such information and belief alleges <br /> 16 that beginning at an exact date that is unknown to plaintiff,but within five(5)years prior to the <br /> 17 filing of this complaint(CCP §338.1),defendants engaged in acts in violation of Health and Safety <br /> 18 Code section 25280 et seq., including but not limited to the following: <br /> 19 a. Failure to submit Underground Storage Tank Permit Application-Form A and <br /> 20 Underground Storage Tank Permit Application-Form B, in violation of California Code of <br /> 21 Regulations,Title 23, section 2711(b); <br /> 22 b. Failure to maintain evidence of financial responsibility for taking corrective action <br /> 23 and from compensating third parities for bodily injury and property damage caused by a release from <br /> 24 an underground storage tank system, in violation of Health and Safety Code section 25292.2(a); <br /> 25 C. Failure to monitor all underground pressurized piping with secondary containment at <br /> 26 least annually at a pressure designated by the manufacturer,in violation of California Code of <br /> 27 Regulations section 2636(0(4); <br /> 28 d. Failure to submit annual monitoring certification,in violation of California Code of <br /> Complaint for Injunction,Civil Penalties and Other Relief Page 3 <br />