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1 of conduct, it will be necessary for FDIC to commence many <br /> 2 successive actions against Defendants, and ,each of them, to <br /> 3 secure compensation for damages sustained;, thus requiring a <br /> 4 multiplicity of suits. <br /> 5 41. Unless Defendants, and each of them:, are enjoined from <br /> 6 continuing their non-responsive course of conduct, FDIC will <br /> 7 suffer irreparable injury, in that the usefulness and economic <br /> a value of the Toga's Property will be substantially diminished. <br /> 9 42. FDIC has no plain, speedy, or adequate remedy at law, <br /> 10 and injunctive relief is expressly authorized by SS526 and 731 of <br /> 11 the Code of Civil Procedure. <br /> 12 43 In maintaining the nuisance, Defendants, and each of <br /> 13 them, are acting with full knowledge of the consequences and <br /> 14 damages being caused to FDIC and the Togo's Property, and their <br /> 15 conduct in creating said contamination was willful, oppressive <br /> 16 and malicious; accordingly, FDIC is entitled to punitive damages <br /> 17 against Defendants, and each of them, in a sum of be determined <br /> 18 at trial. <br /> 19 SAgOND CAUSE OF ACTION FOR PUBLIC _NUISANCE <br /> 20 44. FDIC repeats and realleges> each and every allegation <br /> 21 set forth in Paragraphs 1 through 43, inclusive, of this <br /> 22 Complaint and incorporates them herein by reference as though set <br /> 23 forth in full. <br /> 24 45. The aforementioned nuisance affects, at the same time., <br /> 25 a considerable number of persons in that the subsurface <br /> 26 contamination affecting the Togo's Property presents an imminent <br /> 27 danger of affecting clean groundwater beneath neighboring <br /> 28 properties and affecting the local water supply. The nuisance <br /> -10 <br />