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1 THIRD CAUSE OF ACTION <br />2 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br />(UNLAWFUL AND/OR UNFAIR COMPETITION) <br />3 <br />10. Paragraphs 1 through 9, above are incorporated herein by reference. Plaintiff is informed <br />4 <br />and believes and based on such information and belief alleges that beginning at an exact date that is <br />5 <br />unknown to Plaintiff, but within four (4) years prior to the filing of this Complaint (B&P § 17208), <br />6 <br />Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br />7 <br />Business and Professions Code, sections 17200 et seq. by virtue of the acts described herein, each of <br />8 <br />which constitutes an unlawful and/or unfair business practice. The use of such unlawful and or <br />9 <br />unfair business practices constitutes unfair competition within the meaning of California Business <br />10 <br />and Professions Code, section 17200 et seq. The unlawful and/or unfair business practices <br />11 <br />committed by the Defendants include, but are not limited to: <br />12 <br />a. Violation of Health and Safety Code sections 25100 et seq., as described in <br />13 <br />paragraphs 8 — 8(d) above; and <br />14 <br />b. Violation of Health and Safety Code sections 25500 et seq., as described in <br />15 <br />paragraphs 9 — 9(c) above. <br />16 <br />PRAYER <br />17 <br />WHEREFORE, Plaintiff prays that: <br />18 <br />1. Defendants be permanently restrained and enjoined from engaging in or performing, <br />19 <br />directly or indirectly, any and all of the following acts: <br />20 <br />a. Engaging in any acts in violation of Health and Safety Code section 25100 et seq., <br />21 <br />including but not limited to: <br />22 <br />1. Violation of California Code of Regulations, title 22 section <br />23 <br />66262.34(d)(2); <br />24 <br />2. Violation of California Code of Regulations, title 22 section 66262.40(a); <br />25 <br />3. Violation of California Code of Regulations, title 22 section 66262.42(c); <br />26 I and <br />27 <br />4. Violation of Health and Safety Code section 25160.2(b)(3). <br />28 <br />-4- <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF