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1 61. Each intentional violation by Defendants, and each of them, of the hazardous waste <br />2 handling, training, and storage requirements discovered within the five years of commencing this <br />3 action, exclusive of any applicable tolling periods and those set forth in paragraph 13 herein, <br />4'' subjects Defendants, and each of.themi "to a separate and'4dclitional civil penalty under Health and <br />5 Safety Code section 25189, subdivision (b). <br />6 62. Based on the above, Plaintiff requests injunctive relief against Defendants, and each <br />7 of them, under Health and Safety Code section 25181, and civil penalties against Defendants, and <br />8 each of them, under Health and Safety Code section 25189, subdivision (b), for each intentional <br />9 violation of the hazardous waste handling, training and storage requirements of Chapter 6.5 of <br />10 Division 20 of the Health and*Safety Code section 25100 et seq., and its implementing regulations <br />11 at Title 22 of the California Code of Regulations section 66260.1 et seq., at the Covered <br />12 . Facilities, as set forth in Plaintiff's prayer for relief <br />13 EIGHTH CAUSE OF ACTION <br />14 (Negligent Violations of Hazardous Waste Control Laws for <br />15 Hazardous Waste Handling, Training and Storage Requirements; <br />16 Against all Defendants) <br />17 (Health & Safety Code, §§ 251.00, et seq., and 251.89, subd. (b); <br />18 Cal. Code Regs., Tit. 22, § 66260.1, et seq.) <br />19 63. Plaintiff realleges Paragraphs 1 through 25, 26d. through 26x., and 27 through 28, <br />20 inclusive. <br />21 64. Defendants, and each of them, have negligently violated and continue to violate the <br />22 hazardous waste handling, training and storage requirements of Chapter 6.5 of Division 20 of the <br />23 Health and Safety Code section 25100 et seq., and its implementing regulations at Title 22 of the <br />24 California Code of Regulations section 66260.1 et seq., at the Covered Facilities, and unless <br />25 enjoined by order of the Court, Defendants, and each of them, may or will continue in the course <br />26 of conduct as alleged herein. <br />27 65. Each negligent violation by Defendants, and each of them, of the hazardous waste <br />28 handling, training, and storage requirements discovered within the five years of commencing this <br />19 <br />First Amended Complaint for Preliminary and Permanent Injunction, Civil Penalties and Other Equitable Relief <br />Case No. RG09457686 <br />