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1 Petitioner , CHARLOTTE MADURA, is , and at all times herein <br /> 2 mentioned was , the owner of and in possession of the property <br /> 3 known as 740 Gallery Drive, City of Tracy, State of California. <br /> 4 <br /> 4. Respondents have a clear, present , and ministerial duty to <br /> 5 <br /> remove or cause the removal of the mounds of contaminated soil <br /> 6 excavated and left lying upon the surface of the undeveloped <br /> 7 <br /> property at the corner of Tracy Boulevard and Beechnut Road, City <br /> 8 of Tracy, State of California, and to also remove or cause the <br /> 9 removal of the concrete, i e, and equipment left <br /> P Plying upon said <br /> 10 <br /> property by virtue of their violating Rule 418 "Nuisance" of the <br /> 11 San Joaquin County Air Pollution Control District Rules and <br /> 12 Regulations and Section 41700 of the California Health and Safety <br /> 13 Code to do so. b Despite repeated demands <br /> P P y the petitioners, each <br /> 14 <br /> governmental agency has failed to <br /> perform such duty of <br /> 15 enforcement . <br /> 16 5 , Petitioners have a clear , present , and substantial right <br /> 17 to the performance of respondents ' duty in that they were and are <br /> 18 purchaser of homes and real property at the locations described <br /> 19 in paragraph 3 and did not know of the properties former status <br /> 20 as an oil storage reservoir . <br /> 21 At all times herein mentioned , respondents , RENOWN <br /> 22 ENTERPRISES, TEXACO OIL, ASSOCIATED PIPELINE COMPANY, GETTY OIL, <br /> 23 CHEVRON U.S.A. , and DOES 1 through 100, were the agents and/or <br /> 24 employees of each other , and in doing all the things herein <br /> 25 mentioned were acting within the course and scope of their <br /> 26 authority and/or employment as such agent and/or employee, and <br /> 27 with the permission and consent of the other respondents . <br /> 28 6. Sometime prior to 1960, respondents GETTY OIL, ASSOCIATED <br /> 3 <br />