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I SECOND C&USE OF ACTION 2 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ_(UNLAWFUL AND/OR 3 UNFAIR COMPETITION) 4 I1. Paragraphs 1 through 10 above are incorporated herein by reference. Plaintiff is 5 informed and believes and based on such information and belief alleges that beginning at an 6 exact date that is unknown to plaintiff, but within four(4)years prior to the filing of this 7 complaint, defendants DAVID FISCH and FISCH ENVIRONMENTAL have engaged in acts of 8 unlawful and/or unfair competition prohibited by California Business and Professions Code § 9 17200 - §17208 by virtue of the acts described herein,each of which constitutes and unlawful 10 and/or unfair business practice. 11 12. The use of such unlawful and or unfair business practices constitutes unfair 12 competition within the meaning of§17200 of the California Business and Professions Code. The 13 unlawful and/or unfair business practices committed by the defendants include,but are not 14 limited to: 15 12a. Violations of Chapter 6.7 of the Health and Safety Code described in paragraphs 9 16 and 10 above,inclusive; 17 12b. Violation of Uniform Fire Code Section 105.8 f.3, as adopted by San Joaquin 18 County Code § 4-1000,by cutting into an underground storage tank without an appropriate 19 permit. 20 21 PRAYEg 22 WHEREFORE,Plaintiff prays that- 23 1. Defendants DAVID FISCH AND FISCH ENVIRONMENTAL be permanently 24 restrained and enjoined from engaging in or performing,directly or indirectly, any and all of the 25 following acts,pursuant to Business and Professions Code § 17203 and Health and Safety Code 26 § 25299.01: 27 (a) Engaging in any acts of unfair competition in violation of Business and Professions 28 Code § 17200 et seq, including but not limited to those set forth in paragraphs 11-12, inclusive, 4