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I 66266.81(a)(4)(B). <br />2 b. Engaging in any acts in violation of Health and Safety Code, section 25280 et seq., <br />3 including but not limited to: <br />4 1. Violation of California Code of Regulations, title 23 section 2712(b); <br />5 2. Violation of California Code of Regulations, title 23 section 2636(c)(l); <br />6 3. Violation of California Code of Regulations, title 23 section 2715(e); <br />7 4. Violation of California Code of Regulations, title 23 section 2637(a); and <br />8 5. Violation of California Code of Regulations, title 23 section 2715(f); <br />9 c. Engaging in any of the unlawful acts of unfair competition set forth in the Thud <br />10 Cause of Action of this Complaint, as well as any other violations of the Business and Professions <br />11 Code, section 17200 et seq., including but not limited to: <br />12 1. Violation of Health and Safety Code section 25100 et seq., as described in <br />13 paragraph 7 — 7(d) above; <br />14 2. Violation of Health and Safety Code section 25280 et seq., as described in <br />15 paragraph 8 — 8(e) above; <br />16 2. For violation of First Cause of Action, that Defendants herein be assessed a civil penalty <br />17 of TWENTY-FIVE, THOUSAND DOLLARS ($25,000.00), for each violation, in an amount <br />18 according to proof, pursuant to Health and Safety Code section 25198.2; <br />19 3. For violation of the Second Cause of Action, that Defendants herein be assessed a civil <br />70 penalty of not less than FIVE HUNDRED DOLLARS ($500.00) or more than FIVE THOUSAND <br />21 DOLLARS ($5,000.00) for each underground storage tank system for each day of violation of Health <br />22 and Safety Code, in an amount according to proof, pursuant to Health and Safety Code §25299. <br />23 4. For violation of the Third Cause of Action, that Defendants herein be assessed a civil <br />24 penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br />25 competition, in an amount according to proof, pursuant to Business and Professions Code, section <br />26 17206. <br />27 5. Plaintiff recover its costs and agencies costs. <br />28 <br />-5— _ <br />SECOND AMENDED VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />