COMPLIANCE INFO 2004 - 2012 - Laserfiche WebLink

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i 1 10. Violation of California Code of Regulations, title 23 section 2715(d); 2 11. Violation of Health & Safety Code Section 25284.2; 3 12. Violation of California Code of Regulations, title 23 section 2712(b); 4 13. Violation of California Code of Regulations, title 23 section 2630(d). 5 c. Engaging in any of the unlawful acts of unfair competition set forth in the Third 6 Cause of Action of this Complaint, as well as any other violations of the Business and Professions 7 Code, section 17200 et seq., including but not limited to: 8 1. Violation of Health and Safety Code section 25100 et seq., as described in 9 paragraphs 10 - 10(i) above; 10 2. Violation of Health and Safety Code section 25280 et seq., as described in 11 paragraphs 11 - 11(m) above; 12 2. For violation of First Cause of Action, that Defendants herein be assessed a civil penalty of 13 TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount according 14 to proof, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), pursuant to 15 Health and Safety Code section 25189.2(b); 16 3. For violation of the Second Cause of Action, that Defendants herein be assessed a civil 17 penalty of not less than FIVE HUNDRED DOLLARS ($500.00) or more than FIVE THOUSAND 18 DOLLARS ($5,000.00) for each underground storage tank system for each day of violation of Health 19 and Safety Code 25280 et. Seq., in an amount according to proof, but not less than ONE HUNDRED 20 THOUSAND DOLLARS ($100,000.00), pursuant to Health and Safety Code §25299. 21 4. For violation of the Third Cause of Action, that Defendants herein be assessed a civil 22 penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair 23 competition, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), in an 24 amount according to proof, pursuant to Business and Professions Code, section 17206. 25 5. For investigative, enforcement, and litigation casts incurred by both the Plaintiff and the 26 investigating agency. 27 6. For such other and further relief to the Plaintiff and investigating agency as the nature of 28 7 VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF