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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 />FIRST CAUSE OF ACTION <br />10. Plaintiff realleges paragraphs one through nine inclusive. <br />11. Defendant is liable for civil penalties as set forth in California Health and Safety <br />Code Section 25189(b) for each intentional or negligent violation of rules, regulations, standards <br />or requirements regarding hazardous waste as set forth above. <br />12. Defendant must immediately and permanently be enjoined from further <br />violations of Chapter 6.5. . <br />SECOND CAUSE OF ACTION <br />13. Plaintiff realleges paragraphs one through nine inclusive. <br />14. Defendant is liable for civil penalties as set forth in California Health and Safety <br />Code Section 25189.2(b) for each violation of the rules, regulations, standards or requirements <br />regarding hazardous waste as set forth above. <br />15. Defendant must immediately and permanently be enjoined from further <br />violations of Chapter 6.5. <br />THIRD CAUSE OF ACTION <br />16. Plaintiff realleges paragraphs one through nine inclusive. <br />17. The Defendant is liable for civil penalties as set forth in California Health and <br />Safety Code Section 25514 for each violation of each California Health and Safety Code section <br />set forth above in paragraphs 9(n) — 9(p), above. <br />18. Defendant must immediately and permanently be enjoined from further <br />violations of Chapter 6.95. <br />FOURTH CAUSE OF ACTION <br />19. Plaintiff realleges paragraphs one through 18 inclusive. <br />20. Within the last four (4) years, Defendant has engaged in unlawful acts or <br />practices in the conduct of a business, which acts or practices constitute unfair competition <br />within the meaning of section 17200 of the Business and Professions Code. Such acts or <br />practices include, but are not limited to, those alleged in the first through third causes of action <br />above. <br />-6- <br />COMPLAINT FOR INJUNCTION, CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />