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1 12b. Violations of § 25154 : Operating a facility, to wit: <br /> 2 the facility which generates hazardous waste in violation of <br /> 3 applicable laws and regulations. <br /> 4 12c. Violations of § 25143 . 2 (e) : Application onto land of <br /> 5 recyclable materials. <br /> 6 PRAYER <br /> 7 WHEREFORE, plaintiff prays judgment as follows: <br /> 8 1. For a permanent injunction enjoining defendants from <br /> 9 any unlawful transportation, storage or disposal of any <br /> 10 hazardous waste or recyclable material; <br /> 11 2 . For a permanent injunction restraining defendants and <br /> 12 their agents, employees and representatives, and any and all of <br /> 13 them from operating their business or the activities incidental <br /> 14 to their business in violation of laws regarding hazardous <br /> 15 waste; <br /> 16 3 . With respect to the first cause of action, for civil <br /> 17 penalties provided by Health and Safety Code Section 25189 , <br /> 18 based upon violations of the California Hazardous Waste Control <br /> 19 Act, to-wit: TWENTY-FIVE THOUSAND DOLLARS ($25, 000 . 00) for each <br /> 20 intentional or negligent and TEN THOUSAND DOLLARS ($10, 000. 00) <br /> 21 for all other violations, in an amount according to proof but <br /> 22 not less than ONE MILLION DOLLARS ($1, 000, 000. 00) ; <br /> 23 4 . Plaintiff recover its costs incurred in this action; <br /> 24 5. Plaintiff have such other and further relief as the <br /> 25 nature of this case may require and the Court deems proper to <br /> 26 <br /> 27 <br /> 28 <br /> 5 <br />