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1 29. Beginning on an exact date unknown to plaintiff but within three years of the filing of <br /> 2 this complaint and continuing for an unknown period beyond that time, defendants CHRIS <br /> 3 McDOUGALL, individually and doing business as MARINA WEST MARINE SERVICES and <br /> 4 MARINA WEST MARINE SERVICES maintained on its premises containers of hazardous waste, <br /> 5 to wit: used oil,without placing labels identifying the contents thereof. <br /> 6 30. Beginning on an exact date unknown to plaintiff but within three years of the filing of <br /> 7 this complaint and continuing for an unknown period beyond that time,defendants CHRIS <br /> 8 McDOUGALL, individually and doing business as MARINA WEST MARINE SERVICES and <br /> 9 MARINA WEST MARINE SERVICES did not prepare and maintain a complete contingency plan <br /> 10 and post this plan at a location near a telephone as required by the California Code of Regulations. <br /> 11 FIRST CAUSE OF ACTION <br /> 12 (Violations of Health and Safety Code §25189(c) etc. ) <br /> 13 31. Plaintiff incorporates by reference paragraphs 1 through 30, above <br /> 14 32. The People are informed and believe and based upon such information and belief <br /> 15 allege that,beginning at an exact date unknown to the People,but within three years prior to the <br /> 16' filing of this complaint, defendants CHRIS McDOUGALL, individually and doing business as <br /> 17 MARINA WEST MARINE SERVICES and MARINA WEST MARINES SERVICES have violated <br /> 18 the laws of the State of California by disposing of or causing.the disposal of hazardous waste at an <br /> 19 unauthorized point for said disposal,to wit: disposal of pressure wash residue containing elevated <br /> 20 levels of copper at 6651 Embarcadero Drive, Stockton, San Joaquin County, California, in violation <br /> 21 of Health and Safety Code sections 25189(c) and 25189(d). <br /> 22 SECOND CAUSE OF ACTION <br /> 23 (Violation of Fish and Game Code Section 5650.1) <br /> 24 33. Plaintiff incorporates by reference paragraphs 1 through 32 herein. <br /> 25 34. The People are informed and believe and based upon such information and belief <br /> 26 allege that,beginning at an exact date unknown to the People, but within three years prior to the <br /> 27 filing of this complaint, defendant CHRIS McDOUGALL, individually and doing business as <br /> 28 6. <br />