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0 <br /> 1 <br /> 1 9. Violation of California Code of Regulations,title 23 section 2715(c)(5). <br /> 2 b. Engaging in any of the unlawful acts of unfair competition set forth in the Second <br /> 3 Cause of Action of this Complaint, as well as any other violations of the Business and Professions <br /> 4 Code, section 17200 et seq., including but not limited to: <br /> 5 1. Violation of Health and Safety Code section 25280 et seq., as described in <br /> G paragraphs 8 --8i above. <br /> 7 2. For violation of the First Cause of Action, that Defendants herein be assessed a civil <br /> 8 penalty of not less than FIVE HUNDRED DOLLARS ($500.00) or more than FIVE THOUSAND <br /> 9 DOLLARS ($5,000.00) for each underground storage tank system for each day of violation of Health <br /> 10 and Safety Code 25280 et seq., in an amount according to proof, but not less than ONE HUNDRED <br /> 11 THOUSAND DOLLARS ($100,000.00), pursuant to Health and Safety Code §25299. <br /> 12 3. For violation of the Second Cause of Action,that Defendants herein be assessed a civil <br /> 13 penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br /> 14 competition,but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00),in an <br /> 15 amount according to proof,pursuant to Business and Professions Code, section 17206. <br /> 16 4. For investigative,enforcement, and litigation costs incurred by both the Plaintiff and the <br /> 17 investigating;agency. <br /> 18 5. For such other and further relief to the Plaintiff and investigating agency as the nature of <br /> 19 the:case may require and that the court deems proper to fully dissipate the effects of the unlawful and <br /> 20 unfair acts complained of herein. <br /> 21 <br /> 22 Dated: �zT Respectfully submitted, <br /> 23 JAMES P TT <br /> DISTRIC <br /> 24 <br /> 25 <br /> y: DA D J. IRE <br /> 26 Supervisi g Deputy istrict Attorney <br /> 27 <br /> 28 <br /> -5- <br /> VERIFIED COMPLAINT FOR INUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />