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I <br />3 <br />4- <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />1. Violation of Health and Safety Code section 25100 et seq., as described in <br />paragraph 7 - 7j above; <br />2. Violation of Health and Safety Code section 25280 et seq., as described in <br />paragraph 8 - 81 above; <br />2. For violation of First Cause of Action, that Defendants herein be assessed a civil penalty <br />of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount <br />according to proof, pursuant to Health and Safety Code section 25198.2; <br />3. For violation of the Second Cause of Action, that Defendants herein be assessed a civil <br />penalty of not less than FIVE I-IUNDRED DOLLARS ($500.00) or more than FIVE THOUSAND <br />DOLLARS ($5,000.00) for each underground storage tank system for each day of violation of Health <br />and Safety Code, in an amount according to proof, pursuant to Health and Safety Code §25299. <br />4. For violation of the Third Cause of Action, that Defendants herein be assessed a civil <br />penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br />competition, in an amount according to proof, pursuant to Business and Professions Code, section <br />17206. <br />5. Plaintiff recover its costs and agencies costs. <br />6. Plaintiff have such other and further relief as the nature of the case may require <br />and that the court deems proper to fully dissipate the effects of the unlawful and unfair acts <br />complained of herein. <br />Dated:51 13 <br />Respectfully submitted, <br />JAMEXP. �ILLETT <br />DIS CT/ATTORNEY <br />B}l,,.A'A l ID J. IREY <br />Supervising Deputy District Attorney <br />-7- <br />FIRST AMENDED VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />