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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 />d. Engaging in any of the unlawful acts of unfair competition set forth in the Second <br />Cause of Action of this Complaint, as well as any other violations of the Business and Professions <br />Code, sections17200 et seq., including but not limited to: <br />1. Violation of Health and Safety Code sections 25100 et seq., as described <br />paragraphs 13 —13(i) above; <br />2. Violation of Health and Safety Code sections 25500 et seq., as described in <br />paragraphs 14 —14(g) above; <br />9-1125.3 (a); <br />and <br />3. Violation of Stockton Municipal Code section 13.16.060; <br />4. Violation of Stockton Municipal Code section 13.16.120; <br />5. Violation of Stockton Municipal Code section 13.16.150(B); <br />6. Violation of Health and Safety Code section 5411; <br />7. Violation of San Joaquin County Ordinance Code, title 9 section <br />8. Violation of San Joaquin County Ordinance Code, title 9 section 1125.4; <br />9. Violation of Water Code section 13387. <br />2. For violations within of First Cause of Action, that Defendants herein be assessed a civil <br />penalty of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount <br />according to proof, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), <br />pursuant to Health and Safety Code section 25189.2(b). <br />3. For violation of the Second Cause of Action, that Defendant herein be assessed a civil <br />penalty of TWO THOUSAND DOLLARS ($2,000.00), for each violation per day in which the <br />violation occurred, except as to those knowing violations for which a civil penalty of FNE <br />THOUSAND DOLLARS ($5,000.00), for each violation per day should be assessed in a total <br />amount according to proof but no less than ONE HUNDRED THOUSAND DOLLARS <br />($100,000.00), pursuant to Health and Safety Code sections 25515(a) and 25515(b). <br />4. For violations of the Third Cause of Action, that Defendants herein be assessed a civil <br />penalty of TWENTY- FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount <br />-9- <br />