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2 <br />0 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />"responsible corporate officer doctrine" for violations of law committed by Target as alleged <br />herein. <br />JURISDICTION AND VENUE <br />12. Venue is proper in this county pursuant to California Health and Safety Code sections <br />25183 and 25516, in that the violations alleged in this Complaint occurred in the County of <br />Alameda and throughout the State of California. This court has jurisdiction pursuant to Article 6; <br />section 10 of the California Constitution and section 393 of the Code of Civil Procedure, <br />13. Plaintiff and Target have entered into a series of agreements to toll any applicable <br />statutes of limitation. As a result of those agreements, a total of 820 days (the "Tolling Period") <br />will not be included in computing the time limited by any statutes of limitation applicable to the <br />causes of action brought against Target based on claims covered by the tolling agreement. Those <br />claims include the claims alleged in this action against Target. <br />STATUTORY AND REGULATORY BACKGROUND <br />14. The State of California has enacted a comprehensive statutory and regulatory <br />framework governing the generation, handling, treatment, storage, transportation, and disposal of <br />hazardous waste. This framework, contained in Chapter 6.5 of Division 20 of the Health and <br />Safety Code section 25100 et seq. ("Chapter 6.5") and its implementing regulations, which are <br />found at Title 22 of the California Code of Regulations section 66260.1 et seq., mandates a <br />"cradle to grave" system known as the Hazardous Waste Control Law ("HWCL"). The HWCL <br />system is maintained to record the generation, registration, tracking, storage, treatment, and <br />disposal of hazardous waste and to provide for the protection of the public and the environment . <br />from the potential risks posed by hazardous waste. <br />15. The State of California has enacted a comprehensive statutory and regulatory <br />framework for the notification, handling, training and spill/release reporting of hazardous <br />materials. This framework is contained in Chapter 6.95 of the Health and Safety Code section <br />25500 et seq. ("Chapter 6.95") and its implementing regulations, known as the Hazardous <br />Materials Release Response Plans and Inventory Law. In order to better inform the public and to <br />assist emergency responders, Chapter 6.95 has, for over twenty (20) years, mandated that basic <br />4 <br />Amended Complaint for Preliminary and Permanent <br />Case No. RGI <br />and Other <br />