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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 />24. Plaintiff is informed and believes, and thereupon alleges, that at all times relevant to <br />this Complaint each of the Covered Facilities generated hazardous waste during every ninety (90) <br />day period. <br />25. Examples of acts and/or omissions committed by Defendants which constitute <br />violations of California environmental laws and regulations are listed in the subparagraphs below. <br />These instances of violations of California law are not an exhaustive. list of violations but are <br />alleged herein by way of examples of past, ongoing and persistent violations: <br />a. On June 26, 2009, Defendants, at a Covered Facility in Alameda County, <br />disposed mercury -containing light bulbs, batteries, and ignitable aerosol wastes into a trash <br />compactor for transportation by a garbage hauler not registered to transport hazardous waste, and <br />bound for a point not authorized to receive hazardous waste or universal waste. <br />b. On June 17, 2009, Defendants, at a Covered Facility in Alameda County, <br />disposed photo processing waste and ignitable aerosol waste into a trash compactor for <br />transportation by a garbage hauler not registered to transport hazardous waste, and bound for a <br />point not authorized to receive hazardous waste or universal waste. <br />C. On May 27, 2009, Defendants, at a Covered Facility in Monterey County, <br />disposed ignitable aerosol wastes, regulated electronic waste ("e -waste"), mercury -containing <br />light bulbs, and other hazardous waste into a trash compactor for transportation by a garbage <br />hauler not registered to transport hazardous waste, and bound for a point not authorized to receive <br />hazardous waste, a -waste or other universal waste. <br />d. On May 21, 2009, Defendants, at a Covered Facility in Alameda County, <br />disposed photo processing waste, ignitable aerosol wastes, canisters of propane, a -waste, <br />mercury -containing light bulbs, corrosive liquid waste, medical waste, and other hazardous waste <br />into a trash compactor for transportation by a garbage hauler not registered to transport hazardous <br />waste, and bound for a point not authorized. to receive hazardous waste, a -waste or other universal <br />waste. <br />e. On May 14, 2009, Defendants, at a Covered Facility in Alameda County, <br />disposed ignitable aerosol waste, e -waste, a mercury -containing light bulb and other universal <br />7 <br />First <br />Case No. RG09457686 <br />and Other Equitable Relief <br />