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i • <br /> 1 bb. Failed to record results of each inspection by the designated underground storage <br /> 2 tank operator in a monthly inspection report, in violation of California Code of Regulations,title 23 <br /> 3 section 2715(c);. <br /> 4 <br /> 5 THIRD CAUSE OF ACTION <br /> 6 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> 7 (UNLAWFUL AND/OR UNFAIR COMPETITION) <br /> 8 18. Paragraphs 1 through 17,above are incorporated herein by reference. Plaintiff is <br /> 9 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 10 date that is unknown to Plaintiff,but within four(4)years prior to the filing of this Complaint(B&P <br /> 11 §17208),Defendants have engaged in acts unlawful and/or unfair competition prohibited by <br /> 12 California Business and Professions Code, section 17200 et seq. by virtue of the acts described <br /> 13 herein, each of which constitutes an unlawful and/or unfair business practice. <br /> 14 19. The use of such unlawful and or unfair business practices constitutes unfair competition <br /> 15 within the meaning of California Business and Professions Code,section 17200 et seq. The unlawful <br /> 16 and/or unfair business practices committed by the Defendants include,but are not limited to: <br /> 17 a. Violation of Health and Safety Code section 25100 et seq., as described in <br /> 18 paragraph 16 - 16g above;and <br /> 19 b. Violation of Health and Safety Code section 25280 et seq., as described in <br /> 20 paragraph 17- 17bb above. <br /> 21 PRAYER <br /> 22 WHEREFORE,Plaintiff prays that: <br /> 23 1. Defendants be permanently restrained and enjoined from engaging in or performing, <br /> 24 directly or indirectly, any and all of the following acts: <br /> 25 a. Engaging in any acts in violation of Health and Safety Code section 25100 et seq., <br /> 26 including but not limited to: <br /> 27 1. Violation of California Code of Regulations,title 22 section 66262.12(a); <br /> 28 2. Violation of California Code of Regulations,title 22 section 66262.34(d); <br /> 8 <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />