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I b. Engaging in any acts in violation of Health and Safety Code section 25100 et seq., <br />2 including but not limited to: <br />3 1. Violation of California Code of Regulations, title 22 section 66262.12(a); <br />i <br />4 2. Violation of California Code of Regulations, title 22 section <br />5 66262.34(d)(2). <br />6 c. Engaging in any of the unlawful acts of unfair competition set forth in the Third <br />7 Cause of Action of this Complaint, as well as any other violations of the Business and Professions <br />8 Code, sectionl7200 et seq., including but not limited to: <br />9 1. Violation of Health and Safety Code section 25280 et seq., as described in <br />10 paragraphs 16 —16s above; <br />11 2. Violation of Health and Safety Code section 25100 et Seq., as described <br />12 paragraphs 17 —17b above. <br />13 2. For violations within the First Cause of Action, that that ]Defendants herein be assessed a <br />14 civil penalty of not less than FIVE HUNDRED DOLLARS ($500.00) or more than FIVE <br />15 THOUSAND DOLLARS ($5,000.00) for each underground storage tank system for each day of <br />16 violation of Health and Safety Code 25280 et seq., in an amount according to proof, but not less than <br />17 ONE HUNDRED "THOUSAND DOLLARS ($100,000.00), pursuant to Health and Safety Code <br />18 §25299. <br />19 3. For violations within of Second Cause of Action, that Defendants herein be assessed a <br />20 civil penalty of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an <br />21 amount according to proof, but not less than ONE HUNDRED THOUSAND DOLLARS <br />22 ($100,000.00), pursuant to Health and Safety Code section 25189.2(b). <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, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), in an <br />26 amount according to proof, pursuant to Business and Professions Code, section 17206. <br />27 5. For investigative, enforcement, and litigation costs incurred by both the Plaintiff and the <br />28 investigating agency. <br />VERIFIED CONFLAINTFORINJTJNCTI�N,CIVIL�, <br />