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1 11 Chapters 6.5 and 6.95 of Division 20, and their implementing regulations, at the Covered <br />2 Facilities. <br />3 VENUE <br />4 8. The Defendant at all times mentioned herein has transacted business within the <br />5 County of Ventura and throughout the State of California. The violations of law hereinafter <br />6 described have been committed within the State of California, with a substantial portion of those <br />7 violations occurring in the County of Ventura. Pursuanito Code of Civil Procedure Section <br />8 393, venue lies in this court. <br />9 GENERAL ALLEGATIONS <br />10 9. Since May 1, 2003, Plaintiff is informed and believes and thereupon alleges that <br />.11 Defendant engaged in the following actions and omissions at and from the Covered Facilities: <br />12 a. Delivered, or otherwise transferred possession of, hazardous waste to a <br />13 person or entity that was not properly licensed and registered to transport hazardous waste, in <br />14 violation of California Health and Safety Code section 25163(a)(1); <br />15 b. Transported hazardous waste without being properly licensed and <br />16 registered to transport hazardous waste, in violation of California Health and Safety Code <br />17 section 25163(a)(1); <br />18 C. Disposed, or caused the disposal of, hazardous waste at a point not <br />19 authorized, in violation of Health and Safety Code section 25189; <br />20 d. Stored hazardous waste beyond the time permitted by law at a facility <br />21 which did not have a hazardous waste storage permit from the California Department of Toxic <br />22 Substances Control, in violation of California Code of Regulations, Title 22, section <br />23 66262.34.; <br />24 e. Failed to properly and timely dispose of accumulated hazardous waste at <br />25 least once every ninety (90) days, in violation of California Code of Regulations, Title 22, <br />26 section 66262.34; and failed to provide to the Department of Toxic Substances Control proof <br />27 of disposal at least once every ninety (90) days by making available for review copies of <br />28 hazardous waste manifests as required by law; <br />-3- <br />COMPLAINT FOR INJUNCTION, CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />