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I protection, including, but not limited to, California Nater- Code <br /> 2 sections 13271, and 13272, California Fish and Game Cade section <br /> 3 5650, and California Health and Safety Cade sections 25280 et <br /> 4 seq. , by causing or permitting hazardous contaminants to be <br /> 5 discharged or released into the .soil. and groundwater at the <br /> 6 Togo"s Property as alleged above. <br /> 7 71. As a proximate• result of the Defendants failure to <br /> 8 comply with applicable statutes and regulations, City and :FDIC <br /> 9 have and continue to incur expenses, losses and damages as set <br /> 10 forth above. <br /> 11 SIXTH CAUSE OF ACTION FOR DECLARATORY RELIBF <br /> 12 72. FDIC repeats and realleges each and every allegation <br /> 13 set forth in Paragraphs l through 71, inclusive, of this <br /> 14 Complaint and incorporates them herein by reference as though set <br /> 15 forth in full. <br /> 6 73. A dispute currently exists among the parties to this <br /> 17 action concerning the extent of the liability of Defendants, and <br /> 18 each of them, for the subsurface contamination currently <br /> 19 affecting the Togo`s Property. FDIC contendsthatDefendants are , <br /> 20 jointly and severally liable for all damages caused to the Togo's <br /> 21 Property by the subsurface contamination, and for all costs <br /> 22 incurred in investigating, testing, abating, and remediating the <br /> 23 damage. Defendants, and Ieach of them, deny any liability for <br /> 24 said contamination and attendant cleanup; costs <br /> 25 74. Based upon the: foregoing, FDIC request that this Court <br /> U enter a judgment declaringthe rights and legal relations of the <br /> 27 interested parties in this action. <br /> 28, WHEREFORE FDIC prays judgment against Defendants, and each <br /> -1'6�- <br />