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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />.13 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />4. Violation of Health and Safety Code Section 25284.2; <br />5. Violation of California Code of Regulations title 23, section 2715; <br />6. Violation of California Code of Regulations title 23, section 2632(b); <br />7. Violation of California Code of Regulations title 23, section 2712(1); <br />8. Violation of California Code of Regulations title 23, section 2712(b); <br />9. Violation of Health and Safety Code Section 25284. <br />c. Engaging in any of the unlawful acts of unfair competition set forth in the Third <br />Cause of Action of this Complaint, as well as any other violations of the Business and Professions <br />Code, section 17200 et seq., including but not limited to: <br />1. Violation of Health and Safety Code section 25100 et seq., as described in <br />paragraphs 22 - 22(1) above; <br />2. Violation of Health and Safety Code section 25280 et seq., as described in <br />paragraphs 23 - 230) above; <br />2. For violation of First Cause of Action, that Defendants herein be assessed a civil penalty of <br />TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount according <br />to proof, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), pursuant to <br />Health and Safety Code section 25189.2(b); <br />3. For violation of the Second Cause of Action, that Defendants herein be assessed a civil <br />penalty of not less than FIVE HUNDRED DOLLARS ($500.00) or more than FIVE THOUSAND <br />DOLLARS ($5,000.00) for each underground storage tank system for each day of violation of Health <br />and Safety Code 25280 et. Seq., in an amount according to proof, but not less than ONE HUNDRED <br />THOUSAND DOLLARS ($100,000.00), pursuant to Health and Safety Code §25299. <br />4. For violation of the Third Cause of Action, that Defendants herein be assessed a civil <br />penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br />competition, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), in an <br />amount according to proof, pursuant to Business and Professions Code, section 17206. <br />5. For investigative, enforcement, and litigation casts incurred by both the Plaintiff and the <br />investigating agency. <br />