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1 . complaint to show their true names and capacities when <br /> 2 ascertained. Plaintiff is informed and believes and thereupon <br /> 3 alleges that each of the defendants designated herein as a Doe <br /> 4 is legally responsible in some manner for the events and <br /> 5 happenings alleged in this complaint. <br /> g 7 . When, in this complaint, reference is made to any act <br /> 7 of the defendants, such allegations shall be deemed to mean that <br /> g the officers, directors, agents, employees, or representatives <br /> g of said defendants did, or authorized, such acts, or recklessly <br /> 10 and carelessly failed and omitted to adequately or properly <br /> 11 supervise, control or direct their employees and agents while <br /> 12 engaged in the management, direction, operation, or control of <br /> 13 the affairs of said business organization and did so while <br /> 14 acting within the course and scope of their employment or <br /> 15 agency. <br /> 16 FIRST CAUSE OF ACTION <br /> 17 VIOLATIONS OF HEALTH AND SAFETY <br /> 18 CODE SECTIONS 25100 et seq. <br /> 19 (Hazardous Waste Control Act) <br /> 20 8 . The rules and regulations issued under and pursuant to <br /> 21 the California Hazardous Waste Control Act are set forth in <br /> 22 Title 22 of the California Code of Regulations (CCR) Section <br /> 23 66001 et seq. Wastes and hazardous materials possessed, stored, <br /> 24 and handled by the defendants including, but not limited to, <br /> 25 plating waste, corrosive (high and low ph) waste, cyanide, <br /> 26 copper, zinc and lead, referred to herein meet the definition of <br /> 27 hazardous waste as defined in said regulations and/or Health and <br /> 28 Safety Code § 25117 . <br /> 113 <br />