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I STATION AND CONVENIENCE STORE, located at 14931 N. FLAG CITY BLVD.,LODI, <br /> 2 CALIFORNIA. <br /> 10. Defendant DOES ONE through TWENTY are connected and responsible for the acts <br /> 4 complained of below. Their real names are unknown at this time,and the People will amend this <br /> 5 Complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br /> 6 11. Whenever in this Complaint reference is made to any act of Defendants, such allegation <br /> 7 shall be deemed to mean that Defendants and their officers,agents,employees,or representatives, <br /> 8 did or authorized acts while actively engaged in the management,direction,or control of the affairs <br /> 9 of said Defendants,and while acting within the course and scope of their duties. <br /> 10 FIRST CAUSE OF ACTION <br /> 11 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br /> 12 (UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br /> 13 12. Plaintiff is informed and believes and based on such information and belief,alleges that <br /> 14 beginning at an exact date that is unknown to Plaintiff,but within five(5)years prior to the filing of <br /> 15 this Complaint(CCP §338.1),Defendants engaged in acts in violation of Health and Safety Code, <br /> 16 section 25280 et seq.,including but not limited to the following: <br /> 17 a. Failed to design and construct an underground storage tank system with a <br /> 18 monitoring system capable of detecting the entry of the hazardous substance stored in the primary <br /> 19 containment into the secondary containment,in violation of Health and Safety Code section <br /> 20 25291(b); <br /> 21 b. Failed to maintain monitoring system for water intrusion and for removing the <br /> 22 water,in violation Health and Safety Code section 25291(e); <br /> 23 c. Failed to maintain evidence of financial responsibility, in violation of Health and <br /> 24 Safety Code section 25292.2(a); <br /> 25 d. Failed to maintain secondary containment system which prevented any releases <br /> 26 from flowing to a collection sump located at the low point of underground piping,in violation of <br /> 27 California Code of Regulations,title 23 section 2636(c)(1); <br /> 28 <br /> -3- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />