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1.3.2. On October 10, 1994 Viktron purchased Lika Corporation and continued the circuit board manufacturing at the Facility until June 2002. 1.3.2.1. Viktron abandoned the Facility and filed for bankruptcy on July 15, 2002. 1.3.3. In September 2003, Respondent purchased the Facility from an auction. 1.3.3.1. The California Secretary of State lists the Respondent's Agent for Service as Corporation Service Company doing business in California as CSC-Lawyers Incorporating Service, located at 2730 Gateway Oaks Drive, Suite 100, Sacramento California 95833. (Corporation license number C1592199.) 1.3.3.2. When DTSC Project Manager contacted KRE Properties LLC, she was advised to send correspondence to the Respondent's corporate office address located at 4140 Utica Ridge Road, Bettendorf, Iowa 52722. In addition to KRE Properties, LLC a company called Autotech Technologies LP also uses these same two exact addresses in Bettendorf, Iowa and Carol Stream, Illinois and appears to also do business under the name of Autotech Controls. Another entity using this 4140 Utica Ridge Road, Bettendorf, Iowa address is EZAutomation. According to the U.S. EPA Envirofacts database, this address is associated with AVG Automation Uticor Technology LP. According to EZAutomation.net, "Shalli Kumar" is the President/CEO and EZAutomation is a division of AVG. On the EZAutomation.net web page Mr. Kumar says "I am easily accessible via email: shalabh@avg.net" 1.3.3.3. According to Legal Opinion No. 2-00-1445, Viktron Limited Partnership v Program Data Incorporated, decision dated November 14, 2001 , IN THE APPELLATE COURT OF ILLINOIS, SECOND DISTRICT, The court finds: "The following facts are taken from the complaint as well as the affidavits submitted by the parties. Viktron is an Illinois limited partnership with its principal place of business in Carol Stream, Illinois. Viktron manufactures printed circuit boards in California, Utah, Florida, and West Chicago. . . .Viktron's chief executive officer, Shalabh Kumar, was present and requested a demonstration of the tester's capabilities on Viktron's circuit boards" [at the Stockton Facility]. 1.3.3.4 According to Legal opinion No. 2-04-0134, a legal decision issued by the Second District of the Illinois Appellate Court in the case Kumar v Bornstein, Shalabh Kumar, is noted as the chief executive officer of a national group of companies, including Viktron Limited Partnership (Viktron). Shalabh Kumar, as chief executive officer for Viktron, was the operator of the Facility and this same Shalabh Kumar is now the chief executive officer of KRE Properties, LLC, the current owner of the property. 1.3.3.5. On August 3, 2006, DTSC issued to Respondent a draft corrective Action Consent Agreement, Docket Number RPDD 06/07 SCC-4361 (Consent Agreement). The Consent Agreement was addressed to Mr. Jim Bowden, Facilities Manager for KRE Properties, LLC. In response, on August 31, 2006, Mr. Bowden notified DTSC that he was no longer employed by Respondent. However, on 2