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I enjoined by order of the Court, Defendant may or will continue committing these acts. <br />2 42. Each act of unauthorized transportation of hazardous waste without a valid <br />3 registration discovered within five (5) years of commencing this action, exclusive of any applicable <br />4 tolling periods and those set forth in paragraph 15 above, subjects Defendant to a separate and <br />5 additional civil penalty under Health and Safety Code section 25189, or alternatively, under section <br />6 25189.2. <br />7 43. Based on the above, the People request injunctive relief against Defendant under <br />8 Health and Safety Code section 25181, and civil penalties under Health and Safety Code section <br />9 25189 or 25189.2, as described in the People's prayer for relief. <br />10 THIRD CAUSE OF ACTION <br />11(Violation of Hazardous Waste Handling and Storage Requirements) <br />(Health & Saf. Code Chapter 6.5 (§ 25100 et seq.); Cal. Code Regs., tit. 22, § 66260.1 et seq.) <br />12 44. The People reallege all previous paragraphs. <br />13 45. Health and Safety Code sections 25189 and 25189.2 prohibit improper hazardous <br />14 waste handling and storage in violation of Chapter 6.5. <br />15 46. Defendant violated the requirements of Chapter 6.5 and its implementing regulations <br />16 at California Code of Regulations, title 22, section 66260.1 et seq., applicable to the Facilities, by <br />17 committing the acts and omissions alleged in paragraph 32; and unless enjoined by order of the <br />18 Court, Defendant may or will continue committing these acts and omissions. <br />19 47. Each violation of the requirements of Chapter 6.5 and its implementing regulations at <br />20 California Code of Regulations, title 22, section 66260.1 et seq., discovered within five (5) years of <br />21 commencing this action, exclusive of any applicable tolling periods and those set forth in paragraph <br />22 15 above, subjects Defendant to a separate and additional civil penalty under Health and Safety Code <br />23 section 25189, or alternatively, under section 25189.2. <br />24 48. Based on the above, the People request injunctive relief against De Cedant under <br />25 Health and Safety Code section 25181, and civil penalties under Health and Safety Code section <br />26 25189 or 25189.2, as described in the People's prayer for relief. <br />27 <br />28 <br />-15- <br />COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL PENALTIES, AND OTHER RELIEF <br />