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I JURISDICTION AND VENUE <br /> 2 13. Venue is proper in this county pursuant to Code of Civil Procedure section 393 and <br /> 3 Health and Safety Code sections 25183 and 25515.6 in that certain of the violations alleged in the <br /> 4 Complaint occurred in the County of Alameda and throughout the State of California. <br /> 5 14. This Court has jurisdiction pursuant to article 6, section 10, of the California <br /> 6 Constitution. <br /> 7 15. The People and Defendant have entered into a series of agreements to toll any <br /> 8 applicable statutes of limitation. As a result of those agreements, the period between October 1, <br /> 9 2017 to February 1, 2019, inclusive, will not be included in computing the time limited by any <br /> 10 statutes of limitation applicable to the causes of action brought against Defendant based on claims <br /> I 1 covered by the tolling agreements. Those claims include the claims alleged in this action against <br /> 12 Defendant. <br /> 13 STATUTORY AND REGULATORY BACKGROUND <br /> 14 16. The State of California has enacted a comprehensive statutory and regulatory <br /> 15 framework for the generation, handling, treatment, storage,transportation, and disposal of hazardous <br /> 16 wastes. This framework—contained in Chapter 6.5 of Division 20 of the Health and Safety Code, <br /> 17 section 25100 et seq., and its implementing regulations, which are found at title 22 of the California <br /> 18 Code of Regulations section 66260.1 et seq.—mandates a"cradle to grave" system known as the <br /> 19 Hazardous Waste Control Law("HWCL''). The HWCL system is maintained to record the <br /> 20 generation,registration,tracking, storage,treatment, and disposal of hazardous wastes, and to <br /> 21 provide for the protection of the public and the environment from present and potential risks posed <br /> 22 by hazardous wastes. <br /> 23 17. The State of California has also enacted a comprehensive statutory and regulatory <br /> 24 framework for the notification,handling, training, and spill/release reporting of hazardous materials. <br /> 25 This framework is contained in Chapter 6.95 of Division 20 of the Health and Safety Code, section <br /> 26 1 25500 et sea.; and its implementing regulations, and is known as the Hazardous Materials Release <br /> 27 Response Plans and Inventory Law. To better inform the public and to assist emergency responders, <br /> 28 Chapter 6.95 has, for over thirty(30) years,mandated that basic information on the location, type, <br /> i <br /> -4- <br /> COMPLAINT FOR INJUNCTIVE RELIEF,CIVIL PENALTIES,AND OTHER RELIEF <br />