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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 />I <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />.%W <br />decision to use their d:rindli__ funds for things ather than i <br />I <br />proper disposal of the _-_za__cus waste. <br />late December _-=5 the, shut their doors ;_t=.cut any <br />notice to ac<rernment agencies c-- their landlord _cnn H—,nkei an: <br />situp walked away from the facility--leav_ng over 12,000 of <br />untreated wastewater and Wither hazardous waste. --'=eV ha -;-e on <br />cccas:ona11_✓ returned tc try to retrieve ecuipmen_ for sale and <br />have made limited inquiry as to cleanup reau'irements and then <br />only after contact from acver=ent agencies. See separately f --'ed <br />declarations. Tests taken over the intervenina "_ricd of time <br />indicate that some of the waste is increasing in =cxic a_•% as -__me <br />goes cn. Details cf tes_ results from samples ta;:e_^_ September =0, <br />1995 and photos are attached as exhibit 1. <br />1. ]DEFENDANTS' HISTORY <br />efendants' h-stcr-: with t'-- San Joaau_n Cc-,:n_v courts _S <br />detailed below: <br />=i A civil Stipulation and Judgment was filed in San Joaquin <br />Count_ Superior Court case number 205047 on May '_, 1988, cop_: <br />attached as Exhibit 2. Defendant Smith signed the Stipulation c__ <br />behalf of RV Circuits Inc.. The terms of the Fina_ Judament <br />included a 5 year in]uric_:On against violation of nazardou5 waste <br />laws, a reauirement that the corporation have corporate <br />procedures to legally stere and dispose of their hazardous waste <br />and in lieu of civil penalties, RV was to spend $:5,000 on <br />