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1 9c. Violation of Title 23, California Code of Regulations <br /> 2 52564 in that defendants managment of the feed lot located at <br /> 3 19051 South McKinly Avenue, Manteca, California failed to <br /> 4 minimize manure from infiltrating the underlying soil . <br /> 5 9d. Violation of Title 23, California Code of Regulations <br /> 6 52561 in that retention ponds and silage pits located at the <br /> 7 feed lot at 19051 South McKinly Avenue are unlined. <br /> 8 9e. Violation of Title 23, California Code of Regulations <br /> 9 52563 in that the feed lot located at 19051 South McKinly Avenue <br /> 10 contaminated wastewater discharge resulted in run off to surface <br /> 11 waters. <br /> 12 <br /> 13 P RAYE R <br /> 14 WHEREFORE, Plaintiff prays that: <br /> 15 1 . Defendants be permanently restrained and enjoined from <br /> 16 engaging in or performing, directly or indirectly, engaging in <br /> 17 any of the acts of unfair competition set forth in paragraphs 9 <br /> 18 through 9e, inclusive, of the First Cause of Action of this <br /> 19 complaint, as well as any other violations of Business and <br /> 20 Professions Code 517200 - 517208, pursuant to Business and <br /> 21 Professions Code 517203 . <br /> 22 2. Defendant herein be assessed a civil penalty of TWO <br /> 23 THOUSAND FIVE HUNDRED DOLLARS ( $2 , 500. 00 ) for each act of unfair <br /> 24 competition, in an amount according to proof but not less than <br /> 25 TWO HUNDRED FIFTY THOUSAND DOLLARS ( $250,000. 00) , pursuant to <br /> 26 Business and Professions Code 517206; <br /> 27 3 . Plaintiff recover its costs. <br /> 28 <br /> 4. <br />