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I JURISDICTION <br /> 2 11. The Defendants transact business within the County of San Joaquin and elsewhere <br /> 3 throughout the State of California. The alleged violations of the law, hereinafter described, have <br /> 4 been carried out within said San Joaquin County and elsewhere throughout the State of California. <br /> 5 The alleged actions of the Defendants and each of them,jointly and separately, as set out below, are <br /> 6 in violation of the law and public policy of the State of California. Unless enjoined and restrained by <br /> 7 an order of this court, the defendants will continue to retain the means to engage in unlawful action <br /> 8 and practices and courses of conduct set out below. <br /> 9 STATEMENT OF THE ACTION <br /> 10 12. The PEOPLE OF THE STATE OF CALIFORNIA seek to prohibit Defendants from <br /> I 1 continuing to dispose of hazardous waste in a manner which violates applicable California law. <br /> 12 Such disposal violates the Health and Safety Code and regulations promulgated thereunder. The <br /> 13 PEOPLE OF THE STATE OF CALIFORNIA seek to prohibit Defendants from continuing their <br /> 14 operations in any manner that violates applicable California law. Moreover, the People seek civil <br /> 15 penalties from Defendants for violation of the Health and Safety Code (pursuant to Health and Safety <br /> 16 Code Chapter 6.5 section 25189 or, alternatively, section 25189.2) and acts of unlawful and/or <br /> 17 unfair competition pursuant California Business and.Professions Code sections 17200 through <br /> 18 17208. <br /> 19 13. The People also seek injunctive relief requiring compliance with applicable laws, <br /> 20 regulations, and administrative orders. <br /> 21 HAZARDOUS WASTE LAWS <br /> 22 14. The State of California has enacted a comprehensive statutory and regulatory <br /> 23 framework for the disposal of hazardous wastes. <br /> 24 15. A substance is a hazardous waste if it poses a.substantial present or potential <br /> 25 hazard to the environment when improperly managed or disposed of(Health and Safety Code 25117 <br /> 26 (a), 25141 (b) (2) .) <br /> 27 16. It is illegal to dispose of hazardous wastes at any location which is not permitted <br /> 28 3 <br />