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1 though set forth in full herein paragraphs 1 through 13 , <br /> 2 inclusive. <br /> 3 15. As set forth above, defendants have unlawfully caused <br /> 4 and permitted hazardous waste to be stored and disposed at 216 <br /> 5 South Center Street, Stockton, California where it constitutes a <br /> 6 condition of pollution and public nuisance, presenting a <br /> 7 potential danger to the public health and safety. <br /> 8 <br /> 9 PRAYER <br /> 10 WHEREFORE, plaintiff prays judgment as follows: <br /> 11 1. For a permanent injunction enjoining defendants from <br /> 12 any unlawful transportation, storage or disposal of any <br /> 13 hazardous substance or waste; and requiring defendants to take <br /> 14 all steps necessary to abate the nuisance and to protect public <br /> 15 health and safety, including but not limited to, site <br /> 16 assessment, cleanup and remediation. <br /> 17 2 . For a permanent injunction restraining defendants and <br /> 18 their agents, employees and representatives, and any and all of <br /> 19 them from operating their business or the activities incidental <br /> 20 to their business in violation of the Hazardous Waste Laws. <br /> 21 3 . With respect to the First Cause of Action, for civil <br /> 22 penalties provided by Health and Safety Code Section 25189 , <br /> 43 based upon violations of the California Hazardous Waste Control <br /> 24 Act, to-wit: TWENTY-FIVE THOUSAND DOLLARS ($25 , 000 . 00) for each <br /> 25 intentional or negligent and TEN THOUSAND DOLLARS ($10; 000. 00) <br /> P8 for all other violations, in an amount according to proof but <br /> 27 not less than FIVE HUNDRED THOUSAND DOLLARS ($500, 000 . 00) . <br /> 28 4 . With respect to the Second Cause of Action, for the <br /> 9 <br />