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1 PRAYER <br /> 2 WHEREFORE, plaintiff prays judgment as follows : <br /> 3 1. For a permanent injunction enjoining defendants from <br /> 4 any unlawful transportation, storage or disposal of any <br /> 5 hazardous substance or waste; and requiring defendants to take <br /> 6 all steps necessary to abate the nuisance and to protect public <br /> 7 health and safety, including but not limited to, requiring <br /> 8 defendants to retest of all sites where defendants have removed <br /> 9 underground storage tanks. <br /> 10 2 . For a permanent injunction restraining defendants and <br /> 11 their agents, employees and representatives, and any and all of <br /> 12 them from operating their business or the activities incidental <br /> 13 to their business in violation of the laws regarding hazardous <br /> 14 waste laws and underground storage tanks. <br /> 15 3 . With respect to the First Cause of Action, for civil <br /> 18 penalties provided by Health and Safety Code Section 25189 , <br /> 17 based upon violations of the California Hazardous Waste Control <br /> 18 Act, to-wit: TWENTY-FIVE THOUSAND DOLLARS ($25 , 000. 00) for each <br /> 19 intentional or negligent and TEN THOUSAND DOLLARS ($10, 000 . 00) <br /> 20 for all other violations, in an amount according to proof but <br /> 21 not less than TWO HUNDRED FIFTY THOUSAND DOLLARS ($250, 000. 00) . <br /> 22 4 . With respect to the Second Cause of Action, for the <br /> 23 civil penalties provided for by Health and Safety Code §25299 , <br /> 24 to-wit: $5, 000 for each violation in an amount according to <br /> 25 proof, but not less than ONE HUNDRED THOUSAND DOLLARS <br /> 26 ($100 , 000. 00) . <br /> 27 5 . With respect to the Third Cause of Action, for the <br /> 28 civil penalties provided for by Business and Professions Code <br /> 8 <br />