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1 21. Violation of California Code of Regulations,title 23 section 2715(e); <br /> 2 22. Violation of California Code of Regulations,title 23 section 2635(b)(2); <br /> 23. Violation of California Code of Regulations,title 23 section 2715(f); <br /> 4 24. Violation of California Code of Regulations,title 23 section 2661; <br /> 5 25. Violation of Health and Safety Code section 25291(f); <br /> 6 26. Violation of California Code of Regulations,title 23 section 2650(c); <br /> 7 27. Violation of California Code of Regulations,title 23 section 2650(e); and <br /> 8 28. Violation of California Code of Regulations,title 23 section 2715(c);. <br /> 9 c. Engaging in any of the unlawful acts of unfair competition set forth in the Third <br /> 10 Cause of Action of this Complaint,as well as any other violations of the Business and Professions <br /> 11 Code,section 17200 et seq.,including but not limited to: <br /> 12 1. Violation of Health and Safety Code section 25100 et seq.,as described in <br /> 13 paragraph 16- 16g above; <br /> 14 2. Violation of Health and Safety Code section 25280 et seq., as described in <br /> 15 paragraph 17- 17bb above; <br /> 16 2. For violation of First Cause of Action,that Defendants herein be assessed a civil penalty of <br /> 17 TWENTY-FIVE THOUSAND DOLLARS ($25,000.00),for each violation,in an amount according <br /> 18 to proof,but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00),pursuant to <br /> 19 Health and Safety Code section 25198.2(b). <br /> 20 3. For violation of the Second Cause of Action,that Defendants herein be assessed a civil <br /> 21 penalty of not less than FIVE HUNDRED DOLLARS($500.00)or more than FIVE THOUSAND <br /> 22 DOLLARS ($5,000.00)for each underground storage tank system for each day of violation of Health <br /> 23 and Safety Code, in an amount according to proof, but not less than ONE HUNDRED THOUSAND <br /> 24 DOLLARS ($100,000.00),pursuant to Health and Safety Code §25299. <br /> 25 4. For violation of the Third Cause of Action,that Defendants herein be assessed a civil <br /> 26 penalty of TWO THOUSAND FIVE HUNDRED DOLLARS($2,500.00), for each act of unfair <br /> 27 competition,but not less than ONE HUNDRED THOUSAND DOLLARS($100,000.00), in an <br /> 28 amount according to proof,pursuant to Business and Professions Code,section 17206. <br /> 10 <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />