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1 1 <br /> 1 8. Defendant DOES 1 through 50 are connected and responsible for the acts complained <br /> 2 of below. Thei real names are unknown at this time, and the People will amend this complaint at a <br /> 3 later date when the true identities of DOES 1 through 50 are discovered. <br /> 4 9. 11 defendants at all times acted as agents of one another. With regard to the conduct <br /> 5 and omissions leged in this Complaint, each of the defendants ratified the actions of the other <br /> 6 defendants. <br /> 7 <br /> 8 FIRST CAUSE OF ACTION <br /> 9 VIOLATION OF HEALTH AND SAFETY <br /> 10 CODE SECTIONS 25100 ET SEQ. <br /> 11 HAZARDOUS WASTE CONTROL ACT <br /> 12 10. 1 laintiff is informed and believes and based upon such information and belief alleges <br /> 13 that beginning an exact date that is unknown to plaintiff, but within five (5) years prior to the <br /> 14 filing of this co plaint, defendants, engaged in acts in violation of Health and Safety Code §25100 <br /> 15 et seq.. The vio ations of Health and Safety Code included but are not limited to the following: <br /> 16 a Violation of Health and Safety Code §25189.5, disposed or caused disposal of <br /> 17 hazardous waste at an unauthorized point. <br /> 18 b Violation of Health and Safety Code §25201(a), stored hazardous waste on <br /> 19 site longer than 0 days without a permit or authorization. <br /> 20 C. Violation of California Code of Regulations, Title 22 §66262.11, failed to <br /> 21 make a hazardo s waste determination. <br /> 22 d. Violation of California Code of Regulations, Title 22 §66265.32, failed to <br /> 23 maintain all com.nunication or alarm systems, spill control, or decontamination equipment. <br /> 24 e. Violation of California Code of Regulations, Title 22 §66262.34, failed to <br /> 25 properly label co itainers of hazardous waste. <br /> 26 f. Violation of California Code of Regulations, Title 22 §66265.173(a), failed to <br /> 27 keep containers c f hazardous waste closed except when adding or removing hazardous waste. <br /> 28 3. <br />