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1 <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 />Fol <br />22 <br />23 <br />24 <br />25 <br />PSI <br />011A <br />28 1 <br />2. Violation of Health and Safety Code section 25280 et seq., as described in <br />paragraph 11 - 11 b above. <br />2. For violation of First Cause of Action, that Defendants herein be assessed a civil penalty of <br />TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount according <br />to proof, but not less than THREE HUNDRED THOUSAND DOLLARS ($300,000.00), pursuant to <br />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 SIX THOUSAND DOLLARS ($6,000.00), for each act of unfair competition, in an <br />amount according to proof, but not less than TWO HUNDRED THOUSAND DOLLARS <br />($200,000.00), pursuant to Business and Professions Code, section 17206. <br />5. Plaintiff recover its costs and agencies costs. <br />6. Plaintiff have such other and further relief as the nature of the case may require and that <br />the court deems proper to fully dissipate the effects of the unlawful and unfair acts complained of <br />herein. <br />Dated: I �/®7 <br />(( Respectfully <br />P Y <br />M0]f-1L11131 <br />VID J. IRE <br />;ing Deputy <br />7 <br />VERIFIED COMPLAINT <br />1d <br />ict Attorney <br />