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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />91. Based on the above, the Department is entified to injunctive relief against Defendants <br />under Health and Safety Code secfion 25181 and civil penalfies under Health and Safety Code <br />secfion 25189, subdivision (b) or section 25189.2, subdivision (b), for each day during which <br />each violation of California Code of Regulations, Title 22, section 66273.34, subdivisions (c) and <br />(d), secfion 66273.33, subdivision (b), 66273.33.5, subdivision (a), and section 66273.35, <br />subdivision (b)(1) occuiTed or continued. <br />REQUEST FOR RELIEF <br />The Department requests that the Court grant the following relief: <br />10 I 1. Enter judgment that Defendants PNA and Does 1 -20 have violated the HWCL, its <br />11 [implementing regulations as alleged in the First thi-ough Fifteenth Causes of Action inclusive; <br />12 j 2. Enter judgment that Defendants PNA and Does 1-20 ai-e liable for civil penalties for <br />13 Ithose violations as authorized by Health and Safety Code section 25189 or, in the alternative, <br />14 ^ Health and Safety Code section 25189.2, not to exceed $25,000 per day per violafion, in an <br />15 ' amount of not less than seventy five thousand dollars ($75,000), according to proof; <br />16 3. Enter temporary restraining orders, preliminary injunctions, permanent injunctions, or <br />17 other orders requiring Defendants PNA and Does 1-20 to comply with the HWCL, the regulafions <br />adopted thereunder, which Defendants are alleged to have violated; <br />4. Grant the Department its costs of suit herein against Defendants PNA and Does 1-20; <br />and <br />19 <br />COMPLAINT FOR CIVIL PENALTIES AND INJUNCTIVE RELIEF