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I FIRST CAUSE OF ACTION <br /> 2 10. Plaintiff realleges paragraphs one through nine inclusive. <br /> 3 11. Defendant is liable for civil penalties as set forth in California Health and Safety <br /> 4 Code Section 25189(b)for each intentional or negligent violation of rules,regulations,standards <br /> 5 or requirements regarding hazardous waste as set forth above. <br /> 6 12. Defendant must immediately and permanently be enjoined from further <br /> 7 violations of Chapter 6.5. . <br /> 8 SECOND CAUSE OF ACTION <br /> 9 13. Plaintiff realleges paragraphs one through nine inclusive. <br /> 10 14. Defendant is liable for civil penalties as set forth in California Health and Safety <br /> 11 Code Section 25189.2(b)for each violation of the rules,regulations,standards or requirements <br /> 12 regarding hazardous waste as set forth above. <br /> 13 15. Defendant must immediately and permanently be enjoined from further <br /> 14 violations of Chapter 6.5. <br /> 15 THIRD CAUSE OF ACTION <br /> 16 16. Plaintiff realleges paragraphs one through nine inclusive. <br /> 17 17. The Defendant is liable for civil penalties as set forth in California Health and <br /> t <br /> 18 Safety Code Section 25514 for each violation of each California Health and Safety Code section <br /> 19 set forth above in paragraphs 9(n)—9(p),above. <br /> 20 18. Defendant must immediately and permanently be enjoined from further <br /> 21 violations of Chapter 6.95. <br /> t <br /> 22 FOURTH CAUSE OF ACTION s <br /> 23 19. Plaintiff realleges paragraphs one through 18 inclusive. <br /> 24 20. Within the last four(4)years,Defendant has engaged in unlawful acts or <br /> 25. practices in the conduct of a business,which acts or practices constitute unfair competition <br /> 26 within the meaning of section 17200 of the Business and Professions Code. Such acts or <br /> 27 practices include,but are not limited to,those alleged in the first through third causes of action <br /> 28 above. <br /> -6- <br /> COMPLAINT FOR INJUNCTION,CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />