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I of the Second Cause of Action of this complaint; 2 (b) Engaging in any acts of violation of Chapter 6.7 of the Health and Safety Code,and 3 that they be required to take such action as affirmatively required by that Chapter; 4 2. Defendants DENNIS ROMERO and SHERRY ROMERO be permanently restrained 5 and enjoined from engaging in or performing, directly or indirectly,any and all of the following 6 acts,pursuant to Health and Safety Code §25299.01: 7 (a) Engaging in any acts of violation of Chapter 6.7 of the Health and Safety Code,and 8 that they be required to take such action as affirmatively required by that Chapter; 9 3. Defendants herein be assessed a civil penalty of not less than FIVE HUNDRED 10 DOLLARS ($500.00)per day per violation of Health and Safety Code Chapter 6.7, in an amount 1 I according to proof,but not less than TWO HUNDRED AND FIFTY THOUSAND 12 ($250,000.00),pursuant to Health and Safety Code §25299; 13 4. Defendants herein be assessed a civil penalty of TWO THOUSAND FIVE 14 HUNDRED DOLLARS ($2,500.00)for each act of unfair competition, in an amount according 15 to proof but not less than TWO HUNDRED AND FIFTY THOUSAND DOLLARS 16 ($250,000.00),pursuant to Business and Professions Code § 17206; 17 5. The San Joaquin County Public Health Services- Environmental Health Division shall 18 be reimbursed for their costs in investigation and prosecuting this action; 19 6. Plaintiff recover its costs; 20 7. Plaintiff have such other and further relief as the nature of the case may require and 21 that the court deems proper to fully dissipate the effects of the unlawful and unfair acts 22 complained of herein. 23 24 DATED: March 17, 1997 Respectfully Submitted, 25 JOHN D. PHILLIPS District Attorney 26 27 By- �FS Y 28 ep District Atto y 5