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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />Defendants, and each of them, under Health and Safety Code section 25514, subdivision (a), for <br />each violation of the required.hazardous materials response plans and inventories and training and <br />updating requirements of Chapter 6.95 of Division 20 of the Health and Safety Code section <br />25500 et seq:; and its implementing regulations, at the CoveredFacilities, as set forth in <br />Plaintiff's prayer for relief. <br />ELEVENTH CAUSE OF ACTION <br />(Knowing Violations of Hazardous Materials Release Response Plans <br />and Inventory Laws; Against all Defendants) <br />(Health & Safety Code, §§ 25503.5, 25504, 25,505 and 25514; <br />Cal. Code Regs., Tit. 19, § 2729) <br />75. Plaintiff realleges Paragraphs 1 through 25, 26y, through 26aa., and 27 through 28, <br />inclusive. <br />76. Defendants, and each of them, knowingly failed to maintain the required hazardous <br />materials response plans and inventories required for the Covered Facilities pursuant to Chapter <br />6.95, Division 20, of the Health and Safety Code,. and unless enjoined by order of the Court, <br />Defendants, and each of them, may or will continue in the course of conduct as alleged herein. <br />77. Each knowing violation by Defendants, and each of them, of California Health and <br />Safety Code sections 25503.5, 25504, 25505, and Title 19 of the California Code of Regulations <br />section 2729, discovered within one year of commencing this action, exclusive of any applicable <br />tolling periods and those set forth in paragraph 13 herein, subjects Defendants, and each of them, <br />to a separate and additional civil penalty under Health and Safety Code section 25514.5(b) for <br />each violation of Chapter 6.95. <br />78. Based on the above, Plaintiff requests injunctive relief against Defendants, and each of <br />them, under Health and Safety Code sections 25116 and 25516.2, and civil penalties against <br />Defendants, and each of them, under Health and Safety Code section 25514, subdivision (b), for <br />each violation of the required hazardous materials response plans and inventories and training and <br />updating requirements of Chapter 6.95 of Division 20 of the Health and Safety Code section <br />22 <br />First <br />Case No. RG09457686 <br />Civil Penalties and <br />