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1 Health and Safety Code section 25189 and 25189.2; <br /> 2 3. For violation of the Second Cause of Action, that Defendants herein be assessed a civil <br /> 3 penalty of not less than FIVE HUNDRED DOLLARS ($500.00) or more than FIVE THOUSAND <br /> 4 DOLLARS ($5,000.00) for each underground storage tank system for each day of violation of Health <br /> 5 and Safety Code, in an amount according to proof,but not less than ONE HUNDRED THOUSAND <br /> 6 DOLLARS ($100,000.00),pursuant to Health and Safety Code §25299. <br /> 7 4. For violation of the Third Cause of Action, that Defendants herein be assessed a civil <br /> 8 penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br /> 9 competition, in an amount according to proof,but not less than ONE HUNDRED THOUSAND <br /> 10 DOLLARS ($100,000.00),pursuant to Business and Professions Code, section 17206. <br /> 11 5. Plaintiff recover its costs and agencies costs. <br /> 12 6. Plaintiff have such other and further relief as the nature of the case may require and that <br /> 13 the court deems proper to fully dissipate the effects of the unlawful and unfair acts complained of <br /> 14 herein. <br /> 15 <br /> 16 Dated: �/l Respectfully submitted, <br /> 17 <br /> 18 JAMES . WIL <br /> 19 DISTRI O EY <br /> 20 <br /> 21 <br /> 22 By: DA J. IREY <br /> S <br /> 23 upervis' Deputy Dis Attorney <br /> 24 <br /> 25 <br /> 26 <br /> 27 <br /> 28 <br /> 6 <br /> VERIFIED COMPLAINT <br />