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1 tained. Plaintiff is informed and believes and thereupon alleges <br /> 2 that each of the defendants designated herein as a Doe is legally <br /> 3 responsible in some manner for the events and happenings alleged <br /> 4 in this compla_nt. <br /> 5 10 . When, in this complaint , reference is made to any act of <br /> 6 the defendants, such allegations shall be deemed to mean that the <br /> 7 officers, directors, agents, employees, or representatives of <br /> 8 said defendants did, or authorized, such acts, and did so while <br /> 9 acting within the course and scope of their employment or agency. <br /> 10 FIRST CAUSE OF ACTION <br /> 11 (HAZARDOUS WASTE CONTROL ACT ) <br /> 12 ACTIONS FOR CIVIL PENALTIES FOR VIOLATING PROVISIONS <br /> OF CHAPTER 6 . 5, DIVISION 20 OF THE HEALTH AND SAFETY <br /> 13 CODE . ( §25189( c ) . <br /> 14 11 . The People reallege and incorporate by reference <br /> 15 paragraphs 1 through 10 . <br /> 16 12 . Section 25189 (c) of the Health and Safety Code provides <br /> 17 as follows: <br /> 18 25189(c) : "Any person who intentionally disposes or <br /> 19 causes the disposal of any hazardous or extremely <br /> .. .hazardous waste at a .point which is not authorized <br /> 20 shall be subject to a civil penalty of not less than <br /> one thousand dollars ( $1, 000 ) or more than twenty- <br /> 21 five thousand dollars ($25, 000 ) for each violation. " <br /> 22 13 . The defendants, beginning at a date unknown to <br /> 23 Plaintiff , but within three years from the date of filing of this <br /> 24 <br /> complaint , and continuing tl, - this date have operated ST <br /> 25 SERVICES in violation of the laws of the State of California as <br /> 26 set forth more fully herein. <br /> 27 14 . Wastes and hazardous materials referred to herein, <br /> 28 possessed, stored, disposed of, and handled by the defendants , <br /> 4. <br />