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} <br />1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />materials are sold to the public in the ordinary course of business. Some of these hazardous <br />materials are used by Defendant at each of Defendant's Facilities in the ordinary course of <br />business. At all times relevant hereto and continuing from and after the date of filing of this <br />Complaint, Defendant also generated regulated quantities of hazardous waste at each of <br />Defendant's Facilities as a result of various causes, including but not limited to, damage to <br />containers, spills and releases of hazardous materials, pharmaceutical and pharmacy waste, photo <br />waste containing silver, and various hazardous wastes generated from customer returns of <br />hazardous products, which must be handled and disposed of as hazardous waste in compliance <br />with the HWCL. <br />22. At all times relevant to this Complaint, Defendant is and was responsible for the <br />operation of Defendant's Facilities. At all times relevant to this Complaint, Defendant is and was <br />aware of and conducted, approved and/or controlled the hazardous -materials, medical -waste, and <br />hazardous -waste management activities at Defendant's Facilities. At all times relevant to this <br />Complaint, Defendant's actions and/or omissions, as part of a continuing course of conduct, are <br />or were the legal cause of the violations alleged herein, and Defendant, or its predecessors, <br />reasonably could have taken action to prevent them. <br />23. Plaintiff is informed and believes, and thereupon alleges, that at all times relevant <br />to this Complaint, Defendant, at each of Defendant's Facilities, generated hazardous waste during <br />every ninety (90) day period. <br />24. Plaintiff is informed and believes and thereupon alleges that Defendant has <br />violated provisions of the following statutes, including implementing regulations associated with <br />each of the statutes and any related permit, rule, standard, or requirement issued or promulgated <br />pursuant to these statutes, at Defendant's Facilities within the time period applicable to this <br />action: Chapter 6.5 of the Health and Safety Code, sections 25100, et seq., Chapter 6.95 of the <br />Health and Safety Code, sections 25500, et seq., Health and Safety Code sections 117600, et seq., <br />and Business and Professions Code sections 17200, et seq. <br />7 <br />Complaint For Permanent Injunction, Civil Penalties And Other Equitable Relief <br />