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E <br />1 <br />2 <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 />ordinances pertaining to hazardous waste generator permits, which thereby constitute unfair <br />competition within the meaning of Business and Professions Code section 17200. <br />PRAYER FOR RELIEF <br />Based on the above, the People request the following relief as to Defendant: <br />1. A Permanent Injunction requiring Defendant to comply with those provisions of <br />Health and Safety Code, Division 20, Chapter 6.5 and implementing regulations, which <br />Defendant is alleged to have violated; <br />2. A Permanent Injunction requiring Defendant to comply with those provisions of <br />Health and Safety Code, Division 20, Chapter 6.95 and implementing regulations, which <br />Defendant is alleged to have violated; <br />3. A Permanent Injunction, issued pursuant to Business and Professions Code section <br />17203, prohibiting Defendant from engaging in activity that violates the provisions of Chapters <br />6.5 and 6.95 of Division 20 of the Health and Safety Code, and Health and Safety Code sections <br />117600, et seq., as alleged in this Complaint which thereby constitute unfair competition within <br />the meaning of Business and Professions Code section 17200; <br />4. Civil penalties against Defendant for each violation of Health and Safety Code <br />section 25189, or alternatively section 25189.2, in an amount according to proof; <br />5. Civil penalties against Defendant pursuant to Health and Safety Code sections <br />25514 and 25515.2, in an amount according to proof, <br />6. Civil penalties against Defendant pursuant to Business and Professions Code <br />section 17206 for each act of unfair competition, in an amount according to proof; <br />7. Plaintiff's costs of inspection, investigation, attorney's fees, enforcement, <br />prosecution, and suit herein; and <br />14 <br />Complaint For Permanent Injunction, Civil Penalties And Other Equitable Relief <br />