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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I c. Engaging in any of the unlawful acts of unfair competition set forth in the Third Cause of Action of this Complaint, as well as any other violations of the Business and Professions Code, section 17200 et seq., including but not limited to: 1. Violation of Health and Safety Code section 25280 et seq., as described in paragraphs 10 —10(v) above; 2. Violation of Health and Safety Code section 25 100 et seq., as described paragraphs 11 — I I (b) above. 2. For violations within the First Cause of Action, that that Defendants herein be assessed a civil penalty of not less than FIVE HUNDRED DOLLARS ($500.00) or more than FIVE THOUSAND DOLLARS ($5,000.00) for each underground storage tank system for each day of violation of Health and Safety Code 25280 et seq., in an amount according to proof, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), pursuant to Health and Safety Code §25299. 3. For violations within of Second Cause of Action, that Defendants herein be assessed a civil penalty of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount according to proof, but not less than ONE HUNDRED THOUSAND DOLLARS ($ 100,000.00), pursuant to Health and Safety Code section 25189.2(b). 4. For violation of the Third Cause of Action, that Defendants herein be assessed a civil penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair competition, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), in an amount according to proof, pursuant to Business and Professions Code, section 17206. ,5. For investigative, enforcement, and litigation costs incurred by both the Plaintiff and the investigating agency. -8- VERIFIED COMPLAINT FOR UNCTION, CIVIL PENALTIES, AND OTHER RELIEF