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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 />11, 111 111115 111 i II i1111111111111r'� 1�1�11�11q!• •iiiii iiiiiiiiiij <br />I complained of below. Their real names are unknown at this time, and the People will amend this <br />I <br />Complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br />9. 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 />lof <br />1 :1 1 <br />OK ns <br />10. Plaintiff is informed and believes and based on such information and belief, alleges that <br />beginning at an exact date that is unknown to Plaintiff, but within five (5) years prior to the filing of <br />a. Failed to annually test the spill containment structure, in violation of Health and <br />b. Failed to implement a monitoring program approved by the local agency and <br />specified in the underground storage tank operating permit, in violation of California Code of <br />Regulations, title 23 section 2632(b); <br />c. Failed to maintain written monitoring and maintenance records on site for a period <br />of at least three (3) years, in violation of California Code of Regulations, title 23 section 2712(b); <br />e. Failed to design and construct an underground storage tank system with a <br />monitoring system capable of detecting the entry of hazardous substance stored in the primary <br />containment into the secondary containment, in violation Health and Safety Code section 25291(b); <br />-3-- - <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTT7-�&,,JVD <br />