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• 12b. ViolatiOIIS of 5 25154 : operating a facility, to wit: <br /> ' • 1 <br /> facility which generates hazardous waste in violation of <br /> 2 the <br /> 3 IaF>plicable laws and tcg��Iations . <br />« 4 12c:. Violations of 25143 . 2 (e) Application onto land of <br /> z-ecyclablc materials. <br /> 6 i PRAYER <br /> 7 I WHEREFORE, plaintiff prays judgment as follows: <br /> 8 1 . For a permanent injunction Enjoining defendants from <br /> 9 any unlawful transportation, storagc or disposal. of any <br /> 10 hazardous waste or recyclable material. ; , <br /> 11 2 . For a permanent injunction rust.rai.ning defendants and <br /> t2 their agents, employees and representatives, and any and all of <br /> 13 I them from operating their business or the activities incidental <br /> 14 I{ ,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 }ied1th and Safcty Code Section 25189, <br /> t8 based upon violations of the California Hazardous Waste Control <br /> 19 Act, to-wit: TWENTY-FIVE THOUSAND DUi,LnitS ($25 , 000. 00) for each <br /> 20 intentional or negligent and TEN THOUSAND DOLLARS ($10, 000 . 00) <br /> 21 f for all other violations, in an amount according to proof but <br /> I <br /> 22 not less than Ur1E MILLION DOLLAR ($1 , 000 , 000 . 00) , <br /> 23 4 . Plaintiff recover its costs incurred in this action; <br /> 24 S . Plaintiff have sur-}t other and further relief as the <br /> 25 nature of this case may require and the Court deems proper tc <br /> 26 <br /> 27 <br /> 211 <br /> 5 <br />