COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

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I FIRST CAUSE OF ACTION 2 10. Plaintiff realleges paragraphs one through nine inclusive. 3 11. Defendant is liable for civil penalties as set forth in California Health and Safety 4 Code Section 25189(b)for each intentional or negligent violation of rules,regulations,standards 5 or requirements regarding hazardous waste as set forth above. 6 12. Defendant must immediately and permanently be enjoined from further 7 violations of Chapter 6.5. . 8 SECOND CAUSE OF ACTION 9 13. Plaintiff realleges paragraphs one through nine inclusive. 10 14. Defendant is liable for civil penalties as set forth in California Health and Safety 11 Code Section 25189.2(b)for each violation of the rules,regulations,standards or requirements 12 regarding hazardous waste as set forth above. 13 15. Defendant must immediately and permanently be enjoined from further 14 violations of Chapter 6.5. 15 THIRD CAUSE OF ACTION 16 16. Plaintiff realleges paragraphs one through nine inclusive. 17 17. The Defendant is liable for civil penalties as set forth in California Health and t 18 Safety Code Section 25514 for each violation of each California Health and Safety Code section 19 set forth above in paragraphs 9(n)—9(p),above. 20 18. Defendant must immediately and permanently be enjoined from further 21 violations of Chapter 6.95. t 22 FOURTH CAUSE OF ACTION s 23 19. Plaintiff realleges paragraphs one through 18 inclusive. 24 20. Within the last four(4)years,Defendant has engaged in unlawful acts or 25. practices in the conduct of a business,which acts or practices constitute unfair competition 26 within the meaning of section 17200 of the Business and Professions Code. Such acts or 27 practices include,but are not limited to,those alleged in the first through third causes of action 28 above. -6- COMPLAINT FOR INJUNCTION,CIVIL PENALTIES AND OTHER EQUITABLE RELIEF