Laserfiche WebLink
I Chapters 6.5 and 6.95 of Division 20,and their implementing regulations,at the Covered <br /> 2 Facilities. <br /> 3 VENUE <br /> 4 8. The Defendant at all times mentioned herein has transacted business within the <br /> 5 County of Ventura and throughout the State of California. The violations of law hereinafter <br /> 6 described have been committed within the State of California,with a substantial portion of those <br /> 7 violations occurring in the County of Ventura. Pursuant'to Code of Civil Procedure Section <br /> 8 393,venue lies in this court. <br /> 9 GENERAL ALLEGATIONS <br /> 10 9. Since May 1,2003,Plaintiff is informed and believes and thereupon alleges that <br /> . 11 Defendant engaged in the following actions and omissions at and from the Covered Facilities: <br /> 12 a. Delivered,or otherwise transferred possession of,hazardous waste to a <br /> 13 person or entity that was not properly licensed and registered to transport hazardous waste,in <br /> 1 14 violation of California Health and Safety Code section 25163(a)(1); <br /> 15 b. Transported hazardous waste without being properly licensed and <br /> 16 registered to transport hazardous waste,in violation of California Health and Safety Code <br /> s <br /> 17 section 25163(a)(1); <br /> 18 C. Disposed,or caused the disposal of,hazardous waste at a point not <br /> 19 authorized,in violation of Health and Safety Code section 25189; f <br /> 20 d. Stored hazardous waste beyond the time permitted by law at a facility <br /> 21 which did not have a hazardous waste storage permit from the California Department of Toxic <br /> 22 Substances Control, in violation of California Code of Regulations,Title 22,section <br /> 23 66262.34.; <br /> 24 e. Failed to properly and timely dispose of accumulated hazardous waste at <br /> 25 least once every ninety(90)days, in violation of California Code of Regulations,Title 22, <br /> 26 section 66262.34;and failed to provide to the Department of Toxic Substances Control proof <br /> E <br /> 27 of disposal at least once every ninety(90)days by making available for review copies of - <br /> a <br /> 28 hazardous waste manifests as required by law; 3 <br /> -3- <br /> COMPLAINT FOR INJUNCTION,CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />