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4638
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2900 - Site Mitigation Program
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PR0545863
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COMPLIANCE INFO
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Last modified
6/14/2021 12:04:45 PM
Creation date
6/14/2021 11:49:08 AM
Metadata
Fields
Template:
EHD - Public
ProgramCode
2900 - Site Mitigation Program
File Section
COMPLIANCE INFO
RECORD_ID
PR0545863
PE
2950
FACILITY_ID
FA0006073
FACILITY_NAME
PARAGON VENTURES
STREET_NUMBER
4638
STREET_NAME
WATERLOO
STREET_TYPE
RD
City
STOCKTON
Zip
95205
CURRENT_STATUS
02
SITE_LOCATION
4638 WATERLOO RD B
P_LOCATION
99
P_DISTRICT
002
QC Status
Approved
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EHD - Public
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2 <br />3 <br />4 <br />5 <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 />E. THONris5 <br />..CY AT LAW 27 <br />AI MO 0711411 <br />XXX 717 vernnr,(:), <br />349-61.753 <br />34a-casia <br />agreement and injuries sustained by Plaintiff as herein <br />alleged. plaintiff will be required to incur additional <br />medical expense all to his further damage in an amount not <br />ascertained. Plainriff seek leave of the court to amend <br />this complaint to inert -the true amount thereof when ascer- <br />tained. <br />THIRD CAUSE. OF ACTION <br />(GsnerAi ;etligertc *9 to mIrlovel <br />Plaintiff realleges and incorporates the allegations <br />set forth in paragraphs 1 through 11 hereof though fully <br />sot forth. <br />Plaintiff and defendant entered into a lease <br />agreement for the premises herein mentioned. Implied in that <br />agreement was; the condition that the premises were fit for the <br />Purposes and intended uses of Plaintiff, includinA the <br />operation of Plaintiff's business and the supply and avail- <br />ability of drinkable and uncontaminated water for Plaintiff <br />and his employees ;.n the operation of his bu$iness. <br />At all TimeS during the tenancy, Defendant had and <br />r.etained _control over the supply_ of water .to .Plaintiff's <br />Premises and therefore owed a duty to Plaintiff to provide <br />safe and drinkable water to Plaintiff and his emplove-', during <br />the - <br />Defendant MArlowe breached its duty to provide safe <br />And drinkablA water to Plaintiff, failed to perform regular <br />testing of the water to insure that same was safe and drink <br />- <br />ALLEY vs xmovg <br />PIPLAII7 101 WLG1Z Page of_ 1 .4
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