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1 1. Violation of Health and Safety Code section 25100 et seq., as described in <br /> 2 paragraph 15 - 15i above; <br /> 3 2. Violation of Health and Safety Code section 25280 et seq., as described in <br /> 4 paragraph 16 - 16c above. <br /> 5 2. For violation of First Cause of Action,that Defendants herein be assessed a civil penalty of <br /> 6 TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount according <br /> 7 to proof,but not less than THREE HUNDRED THOUSAND DOLLARS ($300,000.00),pursuant to <br /> 8 Health and Safety Code section 25198.2. <br /> 9 3. For violation of the Second Cause of Action,that Defendants herein be assessed a civil <br /> 10 penalty of not less than FIVE HUNDRED DOLLARS ($500.00) or more than FIVE THOUSAND <br /> 11 DOLLARS ($5,000.00) for each underground storage tank system for each day of violation of Health <br /> 12 and Safety Code, in an amount according to proof, but not less than TWO HUNDRED THOUSAND <br /> 13 DOLLARS ($200,000.00),pursuant to Health and Safety Code §25299. <br /> 14 4. For violation of the Third Cause of Action, that Defendants herein be assessed a civil <br /> 15 penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br /> 16 competition, in an amount according to proof, but not less than TWO HUNDRED THOUSAND <br /> 17 DOLLARS ($200,000.00), pursuant to Business and Professions Code, section 17206. <br /> 18 5. Plaintiff recover its costs and agencies costs. <br /> 19 6. Plaintiff have such other and further relief as the nature of the case may require and <br /> 20 that the court deems proper to fully dissipate the effects of the unlawful and unfair acts complained of <br /> 21 herein. <br /> 22 Dated: <br /> 0 Respectfully submitted, <br /> 23 <br /> J P. WILLETT <br /> 24 DI CT ATTORNEY <br /> 25 <br /> 26 B AVI J. IREY <br /> Su rvising eputy Di ict Attorney <br /> 27 <br /> 28 <br /> 7 <br /> VERIFIED COMPLAINT <br />