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1 <br />2 <br />3 <br />4 <br />5 <br />6 <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 />27 <br />28 <br />8. Defendant JASBIR SINGH CHEEMA, individually and as an officer of FIRST <br />EU---;V,GZEE*.V OIL COV.POV,.4.TION, a California c2moration is, and at all times relevant herein <br />was, engaged in the business of GAS STATION/FOOD MART, located at 1612 W. HAMMER <br />LANE, STOCKTON, CALIFORNIA. <br />9. Defendant JASBIR SINGH CHEEMA, individually and as an officer of FIRST <br />i -?f 91) PZ V A Q QrP ArT <br />"I',,',',, .......... <br />FTV ffi-T-� <br />A 11 0-aw e 9• C-14 L <br />complained of below. Their real names are unknown at this time, and the People will amend this <br />at Nv e identities of DOES ONE throu2h TWENTY are discovered. <br />11. Whenever in this Compla - int reference is made to any act of Defendants, such allegation <br />shall be deemed to mean that Defendants and their officers, agents, employees, or representatives, <br />of said Defendants, and while acting within the course and scope of their duties. <br />FIRST CAUSE OF ACTION <br />• 4-441"'U, =-- AJU- "_T <br />�t lig )i of u" mellia M -V to) vnxg x0j.U.- r4m.71 -,4 1101 11ma 1i . ja Vjg�� <br />12. Plaintiff is informed and believes and based on such information and belief alleges that <br />P <br />this Complaint (CCP §338. 1), Defendants engaged in acts in violation of Health and Safety Code, <br />section 25280 et seq., including but not limited to the following: <br />a. Failed to annually test the spill containment structure, in violation of Health and Safety <br />Code section 25284.2; <br />b. Failed to design and construct an underground storage tank system with a monitoring <br />into the secondary containment, in violation of Health and Safety Code section 25291 (b); <br />c. Failed to annually perform automatic line leak detector tightness test, in violation of <br />