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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 />xvii) For violations of §67472(b): 25,000 <br />xviii)For violations of §25154: 25,000 <br />xix) For violation of §25174: 25,000 <br />xx) For violations of 525189.5: 2,737,500 <br />xxi) For violation of §25246: 2,500 <br />c) Violations of the San Joaquin County Air Pollution <br />Control District Rules and Regulations: <br />i) For violation of §412 on October 23, 1985: $ 2,500 <br />ii) For violation of §412 on November 9, 1985: 2,500 <br />iii) For violations of §410 or §412 as set forth in <br />Exhibit 2 at #1 - #20: $50,000 <br />d) Violations of the Stockton Municipal Code: <br />i) For violations of §79.111: $25,000 <br />ii) For violation of §79.508(e): 2,500 <br />7. Total civil penalties sought by paragraphs 1 through 6 <br />amount to TWO HUNDRED FIFTY ONE MILLION FIFTY NINE THOUSAND FIVE <br />HUNDRED DOLLARS ($251,059,500.00). <br />8. That the Department of Health Services, the City of <br />Stockton Fire Department, and San Joaquin Local Health District <br />be reimbursed for their costs in investigating and prosecuting <br />this action. <br />9. Plaintiff recover its cost incurred in this action. <br />10. Plaintiff have such other and further relief as the <br />nature of this case may require and the Court deems proper to <br />fully and successfully dissipate the unlawful acts complained of <br />herein. <br />Dated: <br />20. <br />Respectfully submitted, <br />