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I carried out within said San Joaquin County and elsewhere throughout the State of California. The 2 alleged actions of the defendants and each of them,jointly and separately, as set out below, are in 3 violation of the law and public policy of the State of California. Unless enjoined and restrained by 4 an order of this court, the defendants will continue to retain the means to engage in unlawful action 5 and practices and courses of conduct set out below. 6 DEFENDANTS 7 4. Whenever in this complaint reference is made to any act of defendants, such allegation 8 shall be deemed to mean that defendants and their officers, agents, employees, or representatives, did 9 1 or authorized acts while actively engaged in the management,direction, or control of the affairs of 10 said defendant, and while acting within the course and scope of their duties. 11 5. Defendant VALLEY INDUSTRIES, INC., a corporation is, and at all times relevant 12 herein was, engaged in the business of MANUFACTURER OF TRAILER TOWING PRODUCTS, 13 located at 1313 SOUTH STOCKTON STREET, LODI, CALIFORNIA. 14 6. All defendants at all times acted as agents of one another. With regard to the conduct 15 and omissions alleged in this Complaint, each of the defendants ratified the actions of the other 16 defendants. 17 FIRST CAUSE OF ACTION 18 VIOLATION OF HEALTH AND SAFETY CODE SECTIONS 25100 ET SEQ. 19 HAZARDOUS WASTE CONTROL ACT 20 7. 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 five (5)years prior to the filing of 22 this complaint, defendants, engaged in acts in violation of Health and Safety Code §25100 et seq.. 23 The violations of Health and Safety Code included but are not limited to the following: 24 a. Violation of Health and Safety Code §25189.5, disposed or caused disposal of 25 hazardous waste at an unauthorized point. 26 b. Violation of Health and Safety Code §25201(a), stored hazardous waste on site 27 longer than 90 days without a permit or authorization. 28 2.