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0 <br /> 1 failing to obtain a timely permit to remove and close an underground storage tank(UST). <br /> 2 <br /> 3 WHEREFORE,Plaintiff prays that:PRAYER <br /> 4 1. Defendants be permanently retrained and enjoined from engaging in or performing, <br /> 5 directly or indirectly, any and all of the following acts: <br /> 6 (b) Engaging in any acts of violation of Chapter 6.7 and Chapter 6.75 of the Health and <br /> 7 Safety Code, and be required to take such action as affirmatively required by that Chapter, <br /> 8 2. Defendants herein be assessed a civil penalty of not less than FIVE THOUSAND <br /> 9 DOLLARS ($5,000.00) per day per violation of Health and Safety Code Chapter 6.7,in an <br /> I0 amount according to proof, but not less than TWENTY FIVE THOUSAND FIVE HUNDRED <br /> 11 DOLLARS ($25,000.00),pursuant to Health and Safety Code §252991- <br /> 12 <br /> 25299;12 3. The San Joaquin County Public Health Services-Environmental Health Division <br /> 13 shall be reimbursed for their costs in investigation and prosecuting this action; <br /> 14 4. Plaintiff recover its costs; <br /> 15 5. Plaintiff have such other and further relief as the nature of the case may require <br /> 16 and that the court deems proper to fully dissipate the effects of the unlawful and unfair acts <br /> 17 complained of herein. <br /> 18 <br /> 19 DATED: Respectfully Submitted, <br /> 20 I ' JOHN D. PHMLIPS <br /> District Attorney <br /> 21 <br /> 22 B C <br /> PETER C PUMP Y <br /> 23 Deputy Distriet Attorney <br /> 24 <br /> 25 <br /> 26 <br /> 27 <br /> 28 <br /> HADEPT4HAREDIPPU LYMOUTH SQVAAEconipl 3 <br />