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I <br />2' <br />3 <br />4) <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23' <br />24 <br />25 <br />26 <br />27 <br />28 <br />2. Violation of Health and Safety Code section 25292.2(a); <br />3. Violation of California Code of Regulations, title 23 section 2632(b); <br />4. Violation of California Code of Regulations, title 23 section 2637(a); <br />5. Violation of California Code of Regulations, title 23 section 2638(a); <br />6. Violation of California Code of Regulations, title 23 section 2638(d); <br />7. Violation of California Code of Regulations, title 23 section 2650(b); <br />8. Violation of California Code of Regulations, title 23 section 2712(b); <br />9. Violation of California Code of Regulations, title 23 section 2715(a); <br />10. Violation of California Code of Regulations, title 23 section 2715(e); <br />c. Engaging in any of the unlawful acts of unfair competition set forth in the Second <br />Cause of Action of this Complaint, as well as any other violations of the Business and Professions <br />Code, section 17200 et seq., including but not limited to: <br />1. Violation of Health and Safety Code section 25100 et seq., as described in <br />paragraph 9 - 9e above; <br />2. Violation of Health and Safety Code section 25280 et seq., as described in <br />paragraph 10 - IOj above; <br />2. For violation of First Cause of Action, that Defendants herein be assessed a civil penalty <br />of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount <br />according to proof, but not less than THREE HUNDRED THOUSAND DOLLARS ($300,000.00), <br />pursuant to Health and Safety Code section 25198.2; <br />3. For violation of the Second Cause of Action, that Defendants herein be assessed a civil <br />penalty of not less than FIVE HUNDRED DOLLARS ($500,00) or more than FIVE THOUSAND <br />DOLLARS ($5,000.00) for each underground storage tank system for each day of violation of Health <br />and Safety Code, in an amount according to proof, but not less than TWO HUNDRED THOUSAND <br />DOLLARS ($200,000.00), pursuant to Health and Safety Code §25299. <br />4. For violation of the Third Cause of Action, that Defendants herein be assessed a civil <br />penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br />3 <br />VERIFIED COMPLAINT <br />