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1 2. For violations within the First Cause of Action,that that Defendants herein be assessed a <br /> 2 civil penalty of not less than FIVE HUNDRED DOLLARS($500.00)or more than FIVE <br /> 3 THOUSAND DOLLARS ($5,000.00) for each underground storage tank system for each day of <br /> 4 violation of Health and Safety Code 25280 et seq., in an amount according to proof,but not less than <br /> 5 ONE HUNDRED THOUSAND DOLLARS ($100,000.00),pursuant to Health and Safety Code <br /> 6 §25299. <br /> 7 3. For violation of the Second 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,but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), in an <br /> 10 amount according to proof,pursuant to Business and Professions Code,section 17206. <br /> 11 4. For investigative,enforcement, and litigation costs incurred by both the Plaintiff and the <br /> 12 investigating agency. <br /> 13 5. For such other and further relief to the Plaintiff and investigating agency as the nature of <br /> 14 the case may require and that the court deems proper to fully dissipate the effects of the unlawful and <br /> 1.5 unfair acts complained of herein. <br /> 16 <br /> 17 Dated: ,!� � Respectfully submitted, <br /> JAMES P. W�LVFT <br /> DISTRICT A ONEY <br /> 0 <br /> By. AVID . IREY 1 <br /> 21 Special Deput isqi Attorney <br /> 2; <br /> 24 <br /> 25 <br /> 26 <br /> 27 <br /> 28 <br /> -6- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />