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