COMPLIANCE INFO_2010-2012 - Laserfiche WebLink

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2. Violation of Health and Safety Code section 25100 et seq., as described paragraphs 9 - 9(m) above. For violations within the First Cause of Action, that that Defendants herein be assessed a civil penalty of not less than FIVE HUNDRED DOLLARS ($500.00) or more than FIVE THOUSAND DOLLARS ($5,000.00) for each underground storage tank system for each day of violation of Health and Safety Code 25280 et seq., in an amount according to proof, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), pursuant to Health and Safety Code §25299. For violations within of Second Cause of Action, that Defendants herein be assessed a civil penalty of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount according to proof, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), pursuant to Health and Safety Code section 25189.2(b). For violation of the Third Cause of Action, that Defendants herein be assessed a civil penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair competition, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), in an amount according to proof, pursuant to Business and Professions Code, section 17206. For investigative, enforcement, and litigation costs incurred by both the Plaintiff and the investigating agency. For such other and further relief to the Plaintiff and investigating agency as the nature of the case may require and that the court deems proper to fully dissipate the effects of the unlawful and unfair acts complained of herein. Dated: Respectfully submitted, 4P,f/ LETT DISTRI ATT RNEY y: AVID J. Y Supe ising Deputy District Attorney - 8 - VERIFIED COMPLAINT FOR INJUNCTION. CIVIL PENALTIES. AND OTHER RFT ,TEF I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28