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I refresher courses, for all employees in safety procedures in the event of a release or threatened <br /> 2 release of hazardous material, in violation of Health and Safety Code section 25505(a)(4); <br /> 3 b. Failed to document training electronically or by hard copy and retain for a <br /> 4 minimum of three (3) years, in violation of Health and Safety Code section 25505(a)(4); and <br /> 5 c. Failed to complete and/or submit a hazardous materials inventory for all reportable <br /> 6 materials on site, in violation of Health and Safety Code section 25506(a). <br /> 7 <br /> SECOND CAUSE OF ACTION <br /> 8 <br /> VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> 9 (UNLAWFUL AND/OR UNFAIR COMPETITION) <br /> 10 9. Paragraphs 1 through 8, above are incorporated herein by reference. Plaintiff is informed <br /> 11 and believes and based on such information and belief alleges that beginning at an exact date that is <br /> 12 unknown to Plaintiff, but within four(4) years prior to the filing of this Complaint(B&P §17208), <br /> 13 Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br /> 14 Business and Professions Code, sections 17200 et seq. by virtue of the acts described herein, each of <br /> 15 which constitutes an unlawful and/or unfair business practice. The use of such unlawful and or <br /> 16 unfair business practices constitutes unfair competition within the meaning of California Business <br /> 17 and Professions Code, section 17200 et seq. The unlawful and/or unfair business practices <br /> 18 committed by the Defendants include, but are not limited to: <br /> 19 a. Violation of Health and Safety Code sections 25500 et seq., as described in <br /> 20 paragraphs 8—8(c) above. <br /> 21 PRAYER <br /> 22 WHEREFORE, PIaintiff 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 sections 25500 et seq., <br /> 26 including but not limited to: <br /> 27 1. Violation of Health and Safety Code section 25505(a)(4); and <br /> 28 <br /> -3- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />