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1 xvii ) For violations of §67472 ( b) : 25, 000 <br /> 2 xviii )For violations of §25154 : 25, 000 <br /> 3 xix ) For violation of §25174 : 25 , 000 <br /> 4 xx ) For violations of §25189 . 5: 2, 737, 500 <br /> 5 xxi ) For violation of §25246 : 2, 500 <br /> 6 c ) Violations of the San Joaquin County Air Pollution <br /> 7 Control District Rules and Regulations : <br /> 8 i ) For violation of §412 on October 23 , 1985 : $ 2 , 500 <br /> 9 ii ) For violation of §412 on November 9 , 1985 : 2, 500 <br /> 10 iii ) For violations of §410 or §412 as set forth in <br /> 11 Exhibit 2 at #1 - #20 : $50 , 000 <br /> 12 d) Violations of the Stockton Municipal Code: <br /> 13 i ) For violations of §79 . 111: $25 , 000 <br /> 14 ii ) For violation of §79 . 508 (e ) : 2, 500 <br /> 15 7 . Total civil penalties sought by paragraphs 1 through 6 <br /> 16 amount to TWO HUNDRED FIFTY ONE MILLION FIFTY NINE THOUSAND FIVE <br /> 17 HUNDRED DOLLARS ($251, 059, 500 . 00 ) . <br /> 18 8 . That the Department of Health Services, the City of <br /> 19 Stockton Fire Department, and San Joaquin Local Health District <br /> 20 be reimbursed for their costs in investigating and prosecuting <br /> 21 this action. <br /> 22 9 . Plaintiff recover its cost incurred in this action . <br /> 23 10 . Plaintiff have such other and further relief as the <br /> 24 nature of this case may require and the Court deems proper to <br /> 25 fully and successfully dissipate the unlawful acts complained of <br /> 26 herein. <br /> 27 Dated: <br /> 28 <br /> Respectfully submitted, <br /> 20. <br />