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I complained of below. Their real names are unknown at this time, and the People will amend this <br /> 2 complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br /> 3 21. Whenever in this Complaint reference is made to any act of Defendants, such allegation <br /> 4 shall be deemed to mean that Defendants and their officers, agents, employees, or representatives,did <br /> 5 or authorized acts while actively engaged in the management,direction, or control of the affairs of <br /> 6 said Defendants, and while acting within the course and scope of their duties. <br /> 7 FIRST CAUSE OF ACTION <br /> 8 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. <br /> 9 (HAZARDOUS WASTE CONTROL ACT) <br /> 10 22. Paragraphs 1 through 21, above are incorporated herein by reference. Plaintiff is <br /> 11 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 12 date that is unknown to Plaintiff, but within five(5) years prior to the filing of this <br /> 13 Complaint(CCP §338.1), Defendants engaged in acts in violation of Health and Safety Code §25100 <br /> 14 et seq., including by not limited to the following: <br /> 15 a. Failed to determine if a waste is a hazardous waste in violation of California Code <br /> 16 of Regulations title 22, section 66262.11; <br /> 17 b. Managed a hazardous waste without an EPA ID number, in violation of California <br /> 18 Code of Regulations, title 22 section 66262.12(a); <br /> 19 c. Failed to maintain adequate aisle space in the hazardous waste storage area, to <br /> 20 allow for movement of personnel and response equipment in an emergency in violation of California <br /> 21 Code of Regulations, title 22 section 66265.35; <br /> 22 d. Failed to properly label or mark containers used for onsite accumulation of <br /> 23 hazardous waste, in violation of California Code of Regulations,title 22 section 66262.34(f); <br /> 24 e. Failed to keep hazardous waste containers closed, except when adding or <br /> 25 removing waste, in violation of California Code of Regulations,title 22 section 66265.173(a); <br /> 26 f. Failed to retain copies of signed hazardous waste manifests for at least three(3) <br /> 27 years from the date the waste was accepted by the initial transporter, in violation of California Code <br /> 28 of Regulations, title 22 section 66262.40(a); <br /> 4 <br />