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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 />11 <br />FIRST CAUSE OF i <br />(HAZARDOUS Wi i <br />9. Paragraphs 1 through 8, above are incorporated herein by reference. Plaintiff is informed <br />and believes and based on such information and belief alleges that beginning at an exact date that is <br />unknown to Plaintiff, but within five (5) years prior to the filing of this Complaint (CCP §338.1), <br />Defendants engaged in acts in violation of Health and Safety Code §25100 et seq., including by not <br />limited to the following: <br />a. Failed to retain a copy of consolidated manifest for three (3) years, in violation of <br />Health and Safety Code section 25160.2(b)(3); <br />b. Failed to return compliance certificate to the authorized local agency, in violation <br />of Health and Safety Code section 25187.8(b); <br />c. Failed to mark and manage an emptied container or an inner liner from a container <br />larger than five (5) gallons in capacity, in violation of California Code of Regulations, title 22 <br />section 66261.7(f); <br />d. Failed to determine if that waste is a hazardous waste, in violation of California <br />Code of Regulations, title 22 section 66262.11; <br />e. Failed to retain as a record for at least three (3) years from the date the waste was <br />accepted by the initial transporter, in violation of California Code of Regulations, title 22 section <br />66262.40(a); <br />SECOND CAUSE OF ACTION <br />1 i 1 i 1 i :1 <br />1 ' mong i'•' i3.8 ''ri <br />10. Paragraphs 1 through 9, above are incorporated herein by reference. Plaintiff is informed <br />and believes and based on such information and belief alleges that beginning at an exact date that is <br />unknown to Plaintiff, but within five (5) years prior to the filing of this Complaint (CCP §338.1), <br />Defendants engaged in acts in violation of Health and Safety Code, section 25280 et seq., including <br />but not limited to the following: <br />3 <br />VERIFIED COMPLAINT <br />