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I violation of Health and Safety Code section 25163 and Title 22 of the California Code of <br />2 Regulations section 66263.23, and unless enjoined by order of the Court, Defendants, and each of <br />3 them, may or will continue in the course of conduct as alleged herein. <br />4 57. Each act of unauthorized transportation discoveredwithin five years" of commencing <br />5 'this action, exclusive of any applicable tolling periods and those set forth in paragraph 13 herein, <br />6 subjects Defendants, and each of them, to a separate and additional civil penalty under Health and <br />7 Safety Code section 25189, subdivision (b), for each intentional violation of Health and Safety <br />8 Code section 25163 and Title 22 of the California Code of Regulations section 66263.23. <br />9 58. Based on the above, Plaintiff requests injunctive relief against Defendants, and each <br />10 of them, under Health and Safety Code section 25181, and civil penalties against Defendants, and <br />11 each of them, under Health and Safety Code section 25189.2, subdivision (b), for each strict <br />12 liability violation of Health and Safety Code section 25163 and Title 22 of the California Code of <br />13 Regulations section 66263.23, as set forth in Plaintiff's prayer for relief. <br />14 SEVENTH CAUSE OF ACTION <br />15 (Intentional Violations of Hazardous Waste Control Laws for <br />16 Hazardous Waste handling, Training and Storage Requirements; <br />17 Against all Defendants) <br />18 (Health & Safety Code, §§ 25100, et seq., and 25189, subd. (b);. <br />19 Cal. Code Regs., Tit: 22, § 66260.1; et seq.) <br />20 59. Plaintiff realleges Paragraphs 1 through 25, 26d. through 26x., and 27 through 28, <br />21 inclusive. <br />22 60. Defendants, and each of them, have intentionally violated, and continue to violate, the <br />23 hazardous waste handling, training and storage requirements of Chapter 6.5 of Division 20 of the <br />24 Health and Safety Code section 25100 et seq., and its implementing regulations at Title 22 of the <br />25 California Code of Regulations section 66260.1 et seq., at the Covered Facilities, and unless <br />26 enjoined by order of the Court, Defendants, and each of them, may or will continue in the course <br />27 of conduct as alleged herein. <br />28 <br />18 <br />First Amended Complaint for Preliminary and Permanent Injunction, Civil Penalties and Other Equitable Relief. <br />Case No. RG09457686 <br />