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<br />action, exclusive of any applicable tolling periods andthoseset forth in paragraph 13 herein,
<br />I subjects Defendants, and each of them, to a separate and additional civil penalty under Health&
<br />Safety Code section 25189, subdivision (b).
<br />.66, Based onthe above, Plaintiff requests injilhetiverelief against Defendahts,andeach
<br />of them, under Health & Safety Code section 25181, and civil penalties against Defendants, and
<br />each of them, under•Health and Safety Code section,25189, subdivision (b), for each negligent
<br />violation of the hazardous waste handling, training and storage requirements of Chapter 6.5 of
<br />Division 20 of the Health and Safety Code section 25 100 et seq., and its implementing regulations
<br />at Title 22 of the California Code of Regulations section 66260.1 et seq., at the Covered
<br />Facilities, as set forth in Plaintiff's prayer for relief.
<br />NINTH CAUSE OF ACTION
<br />(Strict Liability for Violations of Hazardous Waste Control Laws for
<br />Hazardous Waste Handling, Training and Storage Requirements;
<br />Against all Defendants)
<br />(Health & Safety Code, §§ 25100, et seq., and 25189.2, subd. (b); .
<br />-Cal. Code Regs., Tit. 22, § 66260.1, ef seq.)
<br />67. Plaintiff realleges Paragraphs 1 through 25, 26d. through 26x., and 27 through 28,
<br />inclusive.
<br />68, Defendants, and each of them, have violated and continue to violate the hazardous
<br />waste handling, training and storage requirements of Chapter 6.5 of Division 20 of the Health and
<br />Safety Code section 25 100 et seq., and its implementing regulations at Title 22 of the California
<br />Code of Regulations section 66260A et seq., at the Covered Facilities, and unless enjoined by
<br />order of the Court, Defendants, and each of them, may or will continue in the course of conduct*
<br />as alleged herein,
<br />69. Each violation by Defendants,, and each of them, of the hazardous waste handling, training,
<br />and storage requirements discovered within the five years of commencing this action, exclusive
<br />of any applicable tolling periods and those set forth in paragraph 13 herein, subjects
<br />iii
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<br />First Amended Complaint for Preliminary and Permanent Injunction, Civil Penalties and Other Equitable Relief
<br />Case No. RG09457686
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