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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 />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />tained. Plaintiff is informed and believes and thereupon alleges <br />that each of the defendants designated herein as a Doe is legally <br />responsible in some manner for the events and happenings alleged <br />in this compla_nt. <br />10. When, in this complaint, reference is made to any act of <br />the defendants, such allegations shall be deemed to mean that the <br />officers, directors, agents, employees, or representatives of <br />said defendants did, or authorized, such acts, and did so while <br />acting within the course and scope of their employment or agency. <br />FIRST CAUSE OF ACTION <br />(HAZARDOUS WASTE CONTROL ACT) <br />ACTIONS FOR CIVIL PENALTIES FOR VIOLATING PROVISIONS <br />OF CHAPTER 6.5, DIVISION 20 OF THE HEALTH AND SAFETY <br />rnnF r��siQor-I <br />11. The People reallege and incorporate by reference <br />paragraphs 1 through 10. <br />12. Section 25189(c) of the Health and Safety Code provides <br />as follows: <br />25189(c): "Any person who intentionally disposes or <br />causes the disposal of any hazardous or extremely <br />hazardous waste at a point which is not authorized <br />shall be subject to a civil penalty of not less than <br />one thousand dollars ($1,000) or more than twenty- <br />five thousand dollars ($25,000) for each violation." <br />13. The defendants, beginning at a date unknown to <br />Plaintiff, but within three years from the date of filing of this <br />complaint, and continuing th- ' this date have operated ST <br />SERVICES in violation of the laws of the State of California as <br />set forth more fully herein. <br />14. Wastes and hazardous materials referred to herein, <br />Possessed, stored, disposed of, and handled by the defendants, <br />4. <br />