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Y <br /> 1 SECOND CAUSE OF ACTION <br /> 2 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> 3 (UNLAWFUL AND/OR UNFAIR COMPETITION) <br /> 4 9. Paragraphs I through 8,above are incorporated herein by reference. Plaintiff is informed <br /> 5 and believes and based on such information and belief alleges that beginning at an exact date that is <br /> 6 unknown to Plaintiff,but within four(4)years prior to the filing of this Complaint(B&P 17208), <br /> 7 Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br /> 8 Business and Professions Code, section 17200 et seq. by virtue of the acts described herein,each of <br /> 9 which constitutes an unlawful and/or unfair business practice. <br /> 10 10. The use of such unlawful and or unfair business practices constitutes unfair competition <br /> 11 within the meaning of California Business and Professions Code,section 17200 et seq. The unlawful <br /> 12 and/or unfair business practices committed by the Defendants include,but are not limited to: <br /> 13 a. Violation of Health and Safety Code section 25280 et seq.,as described in <br /> 14 paragraph 8—8i above. <br /> 15 PRAYER <br /> 16 WHEREFORE,Plaintiff prays that: <br /> 17 1. Defendants be permanently restrained and enjoined from engaging in or performing, <br /> 18 directly or indirectly, any and all of the following acts: <br /> 19 a. Engaging in any acts in violation of Health and Safety Code section 25280 et seq., <br /> 20 including but not limited to: <br /> 21 1. Violation of California Health and Safety Code section 25292.2(a); <br /> 22 2. Violation of California Code of Regulations,title 23 section 2630(d); <br /> 23 3. Violation of California Code of Regulations,title 23 section 2635(b)(1); <br /> 24 4. Violation of California Code of Regulations,title 23 section 2635(b)(2); <br /> 25 5. Violation of California Code of Regulations,title 23 section 2636(0(2); <br /> 26 6. Violation of California Code of Regulations,title 23 section 2638(d); <br /> 27 7. Violation of California Code of Regulations,title 23 section 2712(i); <br /> 28 8. Violation of California Code of Regulations,title 23 section 2715(a)and <br /> -4- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />