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1 FIRST CAUSE OF ACTION <br /> 2 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. <br /> (HAZARDOUS WASTE CONTROL ACT) <br /> 3 <br /> 4 10. Paragraphs 1 through 9, above are incorporated herein by reference. Plaintiff is informed <br /> 5 and believes and based on such information and belief alleges that beginning at an exact date that is <br /> 6 unknown to Plaintiff,but within five(5)years prior to the filing of this Complaint(CCP §338.1), <br /> 7 Defendants engaged in acts in violation of Health and Safety Code §25100 et seq., including by not <br /> 8 limited to the following: <br /> 9 a. Failed to retain a copies of consolidated manifest for at least three(3)years,in <br /> 10 violation of Health and Safety Code section 25160.2(b)(3); <br /> 11 b. Treated, stored, disposed of, transported or offered to transport hazardous waste <br /> 12 without having an Identification Number,in violation of California Code of Regulations,title 22 <br /> 13 section 66262.12(a); <br /> 14 c. Stored hazardous waste onsite longer than one hundred eighty(l 80) days, in <br /> 15 violation of California Code of Regulations, title 22 section 66262.34(d); <br /> 16 d. Failed to label or mark containers used for onsite accumulation of hazardous waste, <br /> 17 in violation of California Code of Regulations,title 22 section 66262.34(f); <br /> 18 e. Failed to retain copies of signed manifest for at least three(3)years from the date <br /> 19 the waste was accepted by the initial transporter, in violation of California Code of Regulations,title <br /> 20 22 section 66262.40(a); <br /> 21 <br /> 22 SECOND CAUSE OF ACTION <br /> 23 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET(UNDERGROUND STSEQ. <br /> STORAGE OF HAZARDOUS SUBSTANCES) <br /> 24 <br /> 25 11. Paragraphs 1 through 10, above are incorporated herein by reference. Plaintiff is <br /> 26 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 27 date that is unknown to Plaintiff,but within five(5)years prior to the filing of this Complaint (CCP <br /> 28 §338.1),Defendants engaged in acts in violation of Health and Safety Code, section 25280 et seq., <br /> 3 <br /> VERIFIED COMPLAINT <br />