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2 <br />11 <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 />action, exclusive of any applicable tolling periods and those set forth in paragraph 13 herein, <br />subjects Defendants, and each of them, to a separate and additional civil penalty under Health & <br />Safety Code section 25189, subdivision (b). <br />66. Based on the above, Plaintiff requests injunctive relief agaiist Defendants, and each <br />of them, under Health & Safety Code section 25181, and civil penalties against Defendants, and <br />each of them, under Health and Safety Code section,25189, subdivision (b), for each negligent <br />violation of the hazardous waste handling, training and storage requirements of Chapter 6.5 of <br />Division 20 of the Health and Safety Code section 25100 et seq., and its implementing regulations <br />at Title 22 of the California Code of Regulations section 66260.1 et seq., at the Covered <br />Facilities, as set forth in Plaintiffs prayer for relief. <br />NINTH CAUSE OF ACTION <br />(Strict Liability for Violations of Hazardous Waste Control Laws for <br />Hazardous Waste Handling, Training and Storage Requirements; <br />Against all Defendants) <br />(Health & Safety Code, §§ 25100, et seq., and 25189.2, subd. (b); <br />Cal. Code Regs., Tit. 22, § 66260.1, et seq.) <br />67. Plaintiff realleges Paragraphs 1 through 25, 26d. through 26x., and 27 through 28, <br />inclusive. <br />68. Defendants, and each of them, have violated and continue to violate the hazardous <br />waste handling, training and storage requirements of Chapter 6.5 of Division 20 of the Health and <br />Safety Code section 25100 et seq., and its implementing regulations at Title 22 of the California <br />Code of Regulations section 66260.1 et seq., at the Covered Facilities, and unless enjoined by <br />order of the Court, Defendants, and each of them, may or will continue in the course of conduct <br />as alleged herein. <br />69. Each violation by Defendants, and each of them, of the hazardous waste handling, training, <br />and storage requirements discovered within the five years of commencing this action, exclusive <br />of any applicable tolling periods and those set forth in paragraph 13 herein, subjects <br />20 <br />for Preliminary and Permanent <br />Case No. RG <br />Equitable Relief <br />