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2  <br />  <br /> 2. In this action, the United States seeks (a) to enjoin the discharge of pollutants into <br />waters of the United States without a permit in violation of CWA section 301(a), 33 U.S.C. § <br />1311(a); (b) to require Defendants, at their own expense and at the direction of EPA, to <br />restore and/or mitigate the damages caused by their unlawful activities; and (c) to require <br />Defendants to pay civil penalties as provided in 33 U.S.C. § 1319(d). <br />JURISDICTION AND VENUE <br /> 3. This Court had jurisdiction over the subject matter of this action pursuant to <br />CWA section 309(b), 33 U.S.C. § 1319(b), and 28 U.S.C. §§ 1331, 1345, and 1355. <br /> 4. Venue is proper in this District of Colorado pursuant to CWA section 309(b), 33 <br />U.S.C. § 1319(b), and 28 U.S.C. § 1391(b) and (c), because the Defendants conduct business <br />in this District and the cause of action alleged herein arose in this District. <br /> 5. Notice of the commencement of this action has been provided to the State of <br />Colorado pursuant to CWA section 309(b), 33 U.S.C. § 1319(b). <br />THE PARTIES <br /> 6. The Plaintiff in this action is the United States of America. Authority to bring this <br />action is vested in the United States Department of Justice pursuant to 28 U.S.C. §§ 516 and <br />519, and 33 U.S.C. § 1366. <br /> 7. Defendant Varca is a corporation organized under the laws of Nevada with a <br />business address of 1630 Ringling Blvd., Sarasota, FL 34236. <br /> 8. Defendant Wildcat is a corporation organized under the laws of Nevada with a <br />business address of 1630 Ringling Blvd., Sarasota, FL 34236. <br />Case 1:16-cv-02008-WYD Document 1 Filed 08/08/16 USDC Colorado Page 2 of 10