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I course of conduct, are and were the legal cause of the violations alleged in this Complaint, and 2 Defendant reasonably could have taken action to prevent them. 3 31. Defendant has violated provisions of the following statutes and regulations at the 4 Facilities within the time period applicable to this action: Chapter 6.5 of the Health and Safety Code 5 (section 25100 et seq.), Chapter 6.95 of the Health and Safety Code (section 25500 et seq.); Civil 6 Code section 1798.81, Business and Professions Code section 17200 et seq., and regulations, 7 permits, rules, standards, and requirements associated with these statutes. 8 32. Defendant caused or performed each of the acts and/or omissions alleged below in 9 violation of California law in the ownership and/or operation of some or all of the Facilities: 10 a. Disposed, or caused the disposal, of any hazardous waste at a point not authorized 11 by law, in violation of Health and Safety Code sections 25189 and 25189.2, 12 including, without limitation, to any front -loader dumpster, trash compactor, 13 dumpster, roll -off bin, drain, sink, or toilet at any of the Facilities, or onto the 14 surface or subsurface of the ground at any unauthorized location in California, or 15 at a landfill or transfer station in California not authorized to receive hazardous 16 waste; 17 b. Allowed hazardous waste to remain at the Facilities, after causing its deposit, at a 18 point not authorized, without immediately filing a report of the deposit with the 19 California Department of Toxic Substances Control ("DTSC") and complying 20 with any order by the DTSC, in violation of Health and Safety Code sections 21 25189, subdivision (d) and 25189.2, subdivision (c); 22 c. Transported hazardous waste to, from and between the Facilities on vehicles by 23 persons that did not hold a valid registration issued by DTSC, in violation of 24 Health and Safety Code section 25163; 25 I d. Transported, or caused to be transported to, from or between the Facilities, any 26 hazardous waste to an unauthorized location in California, in violation of Health 27 and Safety Code sections 25189.5 and 25163; 28 e. Failed to determine, at each Facility, whether each item of waste generated or -7— COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL PENALTIES, AND OTHER RELIEF