COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

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1 7. Pursuant to Health & Safety Code sections 25181 and 25182, the Attorney General of 2 the State of California is authorized, at the request ofthe Department, to commence an action in 3 the name of the People for civil penalties and injunctive relief under the HWCL. The Department 4 has asked the Attorney General to apply to this Court for penalties and an injunction enjoining 5 Defendants from continuing violations ofthe HWCL. 6 8. Defendant PNA is now, and at all times mentioned in this Complaint was, a Delaware 7 Corporation which does and did business in its own capacity and/or through affiliates in the State 8 of California. 9 9. PNA is, and at all times mentioned in this Complaint was, a "person," as defined at 10 Health and Safety Code section 25118. 11 10. PNA is now, and at all times mentioned in this Complaint was, an "owner" and/or 12 "operator," as defined at Califomia Code of Regulations, Title 22, section 66260.10. At all times 13 mentioned in this Complaint, PNA operates or operated in at least one location in California: the 14 Lathrop Facility. PNA is, and at all times relevant to the claims in this Complaint was, legally 15 responsible for compliance with the provisions ofthe Califomia Health and Safety Code, 16 including, but not limited to, Chapter 6.5 of Division 20, and the corresponding implementing 17 regulations, in connection with PNA's ownership and/or operation of the Lathrop Facility. 18 11. When reference is made in this complaint to any act of Defendant PNA, such 19 allegation shall mean that the owners, officers, directors, agents, employees, contractors and 20 representatives of Defendant PNA did or authorized such acts or recklessly and/or negligently 21 failed and omitted to adequately or properly supervise, control, or direct Defendant PNA 22 employees, representatives, or agents while engaged in the management, direction, operation, or 23 control of the affairs of Defendant PNA and did so while acting within the course and scope of 24 their employment or agency. 25 12. Defendants Does 1-20 are the officers, agents, employees, servants or others acting in 26 interest or concert with PNA. The Department is ignorant of the true names of the defendants 1 27 sued herein as Does 1 -20. When the names of these defendants have been ascertained, the 28 Department will seek leave to amend the complaint to substitute the true name of each Doe 1 COMPLAINT FOR CIVIL PENALTIES AND INJUNCTIVE RELIEF ; 1