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<br />Defendants, and each of them, to a separate and additional civil penalty under Health and
<br />Safety Code section 25189.2, subdivision (b).
<br />76. Based on the above, Plaintiff requests injunctive relief against Defendants, and each
<br />ofth6m, under Health andSaf6ty Code section 25 181, Afid'civil obrialtibs agaifinst'Def6hdants, and
<br />each of them, under Health and Safety Code section 25189.2, subdivision (b), for each violation
<br />of the hazardous waste handling, training and storage requirements of Chapter 6,5 of Division 20
<br />of the Health and Safety Code section 25 100 et seq., and its implementing regulations at Title 22
<br />of the California Code of Regulations section 6.6260.1 et seq., at the Covered Facilities, as set
<br />forth in Plaintiff's prayer for relief.
<br />TENTH CAUSE OF ACTION
<br />(Violations of Hazardous Materials Release Response Plans and Inventory Laws;
<br />Against all Defendants)
<br />(Health & Safety Code, §§ 25503.5, 25504, 25505 and 25514;
<br />Cal. Code Regs., Tit. 19, § 2729)
<br />71. Plaintiff realleges Paragraphs I through 25, 26y. through 26a.a., and 27 through 28,
<br />inclusive.
<br />72. Defendants, and each of them, failed to maintain the required hazardous materials
<br />response plans and inventories required for the Covered Facilities pursuant to Chapter 6.95,
<br />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 />73. Each violation by Defendants, and each of them, of California Health and Safety
<br />Code sections 25503.5, 25504, 25505, and Title 19 of the California Code of Regulations section
<br />2729, discovered within one year of commencing this action, exclusive of any applicable tolling
<br />periods and those set forth in paragraph 13 herein; subjects Defendants, and each of them, to a
<br />separate and additional civil penalty under Health and Safety Code section 25514.5, subdivision
<br />(a), for each violation of Chapter 6.95.
<br />74. Based on the above, Plaintiff requests injunctive relief against Defendants, and each
<br />of them, under Health and Safety Code -sections 25116 and 25516.2, and civil penalties against
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<br />First Amended Complaint for Preliminary and Permanent Injunction, Civil Penalties and Other Equitable Relief
<br />Case No. RGO9457686
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