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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 />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />violation of Health and Safety Code section 25163 and Title 22 of the California Code of <br />Regulations section 66263.23, and unless enjoined by order of the Court, Defendants, and each of <br />them, may or will continue in the course of conduct as alleged herein. <br />57. Each act of unauthorized transportation discovered within five years" of commencing <br />this action, exclusive of any applicable tolling periods and those set forth in paragraph 13 herein, <br />subjects Defendants, and each of them, to a separate and additional civil penalty under Health and <br />Safety Code section 25189, subdivision (b), for each intentional violation of Health and Safety <br />Code section 25163 and Title 22 of the California Code of Regulations section 66263.23. <br />58. Based on the above, Plaintiff requests injunctive relief against Defendants, and each <br />of them, under Health and Safety Code section 25181, and civil penalties against Defendants, and <br />each of them, under Health and Safety Code section 25189.2, subdivision (b), for each strict <br />liability violation of Health and Safety Code section 25163 and Title 22 of the California Code of <br />Regulations section 66263.23, asset forth in Plaintiff's prayer for relief. ' <br />SEVENTH CAUSE OF ACTION <br />(Intentional Violations of Hazardous Waste Control Laws for <br />Hazardous Waste Handling, Training and Storage Requirements; <br />Against all Defendants) <br />(Health & Safety Code, §§ 25100, et seq., and 25189, subd. (b);, <br />Cal. Code Regs., Tit: 22, § 66260.1, et seq.) <br />59. Plaintiff realleges Paragraphs 1 through 25, 26d. through 26x., and 27 through 28, <br />inclusive. <br />60. Defendants, and each of them, have intentionally violated, and continue to violate, the <br />hazardous waste handling, training and storage requirements of Chapter 6.5 of Division 20 of the <br />Health and Safety Code section 25100 et seq., and its implementing regulations at Title 22 of the <br />California Code of Regulations section 66260.1 et seq., at the Covered Facilities, and unless <br />enjoined by order of the Court, Defendants, and each of them, may or will continue in the course <br />of conduct as alleged herein. <br />18 <br />Case No. RG09457686 <br />Civil Penalties and Other <br />