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<br />PRAYER FOR RELIEF
<br />WHEREFORE, Plaintiff prays for the following relief as to each Defendant:
<br />A preliminary and permanent injunction requiring Defendants, and each of them, to
<br />comply with those provisions of Health and SafetyCode, Division 20, Chapter 6.5 and
<br />implementing regulations, which Defendants, and each of them, are alleged to have violated;
<br />2. A preliminary and permanent injunction requiring Defendants, and each of them, to
<br />comply with those provisions of Health and Safety Code, Division 20, Chapter 6.95 and
<br />implementing regulations, which Defendants, and each of them, are alleged to have violated;
<br />3. A preliminary and permanent injunction, issued pursuant to Business and Professions
<br />Code section 17203, prohibiting Defendants, and each of them, from engaging in activity that
<br />violates the provisions of Chapter 6.5 and/or 6.95 of Division 20 of the Health and Safety Code,
<br />Health and Safety Code section 117600 et seq., and county and local ordinances pertaining to
<br />hazardous waste generator permits, as alleged in this Complaint, which thereby constitute unfair
<br />competition within the meaning of Business and Professions Code section 17200;
<br />4. . Civil penalties against Defendants, and each of them, pursuant to Health and Safety
<br />Code section 25189, subdivisions (b), (c) and (d), in an amount according to proof.
<br />Civil penalties against Defendants, and each of them, pursuant to section Health and
<br />Safety Code 25189.2, subdivision (b), in an amount according to proof;
<br />Civil penalties against Defendants, and each of them, pursuant to Health and Safety
<br />Code section 25514, subdivision (a), in an amount according to proof,
<br />Civil penalties against Defendants, and each of them, pursuant to Health and Safety
<br />Code section 25514, subdivision (b), in an amount according to proof;
<br />8. Civil penalties against Defendants, and each of them, pursuant to Business and
<br />Professions Code section 17206 for each act of unfair competition engaged in by Defendants, and
<br />each of them, in an amount according to proof,
<br />9. Plaintiff's costs of inspection, investigation, attorneys' fees, enforcement,
<br />prosecution, and suit herein, including but not limited to such costs as are authorized for
<br />reimbursement pursuant to Code of Civil Procedure section 1021.8; and,
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<br />and Permanent
<br />Case No. RGI
<br />Equitable
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