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I violation of the law and public policy of the State of California. Unless enjoined and restrained by 2 an order of this court, the defendants will continue to retain the means to engage in unlawful action 3 and practices and courses of conduct set out below. 4 DEFENDANTS 5 4. Whenever in this complaint reference is made to any act of defendants, such allegation 6 shall be deemed to mean that defendants and its officers, agents, employees, or representatives, did 7 or authorized acts while actively engaged in the management, direction, or control of the affairs of 8 said defendant, and while acting within the course and scope of their duties. 9 5. Defendant JUAN'S AUTO REPAIR, a business of unknown type of organization, is, and 10 at all times relevant herein was, engaged in the business of AUTO REPAIR, located at 1145 SOUTH 11 AURORA ST., STOCKTON, CALIFORNIA. 12 6. Defendant JUAN 0. MORGA is, and at all times relevant herein was, engaged in the 13 business of AUTO REPAIR, located at 1145 SOUTH AURORA, STOCKTON, CALIFORNIA. 14 7. Defendant DOES 1 through 10 are connected and responsible for the acts complained of 15 below. Their real names are unknown at this time, and the People will amend this complaint at a 16 later date when the true identities of DOES 1 through 10 are discovered. 17 FIRST CAUSE OF ACTION 18 VIOLATION OF HEALTH AND SAFETY CODE 19 CHAPTER 6.95 (EMERGENCY BUSINESS RESPONSE PLANS) 20 8. Plaintiff is informed and believes and based upon such information and belief alleges that 21 beginning at an exact date that is unknown to plaintiff, but within one (1)year prior to the filing of 22 this complaint, defendants engaged in acts in violation of Health and Safety Code Chapter 6.95. 23 9. The violations of Health and Safety Code Chapter 6.95 include but are not limited to the 24 following: 25 9a. Violation of Health and Safety Code § 25503.5 by being a business which handles 26 hazardous materials of more than 55 gallons, 500 pounds or 200 cubic feet including but not limited 27 to WASTE OIL, OXYGEN, PETROLEUM NAPHA and not having established a business plan for 28 emergency response for 1145 SOUTH AURORA ST., STOCKTON, CALIFORNIA. H:V10ME%EANTOLINUUAN'S.WPD 2.