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1 2. For violations within the First Cause of Action,that that Defendants herein be assessed a <br /> 2 civil penalty of not less than FIVE HUNDRED DOLLARS($500.00)or more than FIVE <br /> 3 THOUSAND DOLLARS($5,000.00)for each underground storage tank system for each day of <br /> 4 violation of Health and Safety Code 25280 et seq., in an amount according to proof,but not less than <br /> 5 ONE HUNDRED THOUSAND DOLLARS {$100,000.00),pursuant to Health and Safety Code <br /> 6 §25299. <br /> 7 3. For violations within of Second Cause of Action,that Defendants herein be assessed a <br /> 8 civil penalty of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00),for each violation,in an <br /> 9 amount according to proof,but not less than ONE HUNDRED'THOUSAND DOLLARS <br /> 10 {$100,000.00),pursuant to Health and Safety Code section 25189.2(b). <br /> 11 4, For violation of the Third Cause of Action,that Defendants herein be assessed a civil <br /> 12 penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br /> 13 competition,but not less than ONE HUNDRED THOUSAND DOLLARS($100,000.00),in an <br /> 14 amount according to proof,pursuant to Business and Professions Code, section 17206. <br /> 15 5. For investigative,enforcement, and litigation costs incurred by both the Plaintiff and the <br /> 16 investigating agency. <br /> 17 6. For such other and further relief to the Plaintiff and investigating agency as the nature of <br /> 18 the case may require and that the court deems proper to fully dissipate the effects of the unlawful and <br /> 19 unfair acts complained of herein. <br /> 20 <br /> 21 Dated: Respectfully submitted, <br /> JAMES --Wfi:')LETT <br /> 22 DISM T . QRNIFY <br /> 23 <br /> 24 B W'AVID J. E <br /> SWprervising Deputy District Attorney <br /> 25 <br /> 26 <br /> 27 <br /> 28 <br /> .......... <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />