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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <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 />of them, and their agents, employees and representatives, and any <br />and all of them from any unlawful hauling, disposing of, or <br />storing of any hazardous substance or waste; and requiring defen- <br />dants to take all steps necessary to protect public health and <br />safety and dome;. . livestock or wildlife. <br />2. For a final and permanent injunction restraining defen- <br />dants, and each of them, and their agents, employees and repre- <br />sentatives, and any 9 all of them from operating their business <br />or the activities i'i. :ental to their business in violation of <br />the Hazardous Materials and Waste Laws and in a condition of <br />pollution and public nuisance dangerous to the public health and <br />safety. <br />3. With respect to the First Cause of Action for civil <br />penalties provided by Health and Safety Code Section 25189, <br />based upon violations of the California Hazardous Waste Control <br />Act, to -wit: Twenty -Five Thousand Dollars ($25,000.00) for each <br />separate violation; <br />(a) The People pray for $27,375,000 for the violation of <br />§25189(c). <br />4. With respect to the Second Cause of Action for civil <br />penalties as provided by Health and Safety Code §25189, based <br />upon violations of the California Hazardous Waste Control Act and <br />the regulations promulgated pursuant to said act, to -wit: <br />Twenty -Five Thousand Dollars ($25,000.00) for each separate <br />violation; <br />a) For violations of §66508 $27,375,000 <br />b) For violation of §67100: 25,000 <br />17. <br />