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I . <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />1.6 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22' <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />25500 et seq., and its implementing regulations, at the Covered Facilities, as set forth in <br />I Plaintiff s prayer, for relief. <br />TWELFTH CAUSE OF ACTION <br />. 1. (Vi6ittions of Unfair 'COnipetition LaW§; Against all Defendants* <br />Bu's. & Prof. Code §§ 17200 - 17208) <br />79. Plaintiff realleges paragraphs 1 through 78, inclusive. <br />80. Within four (4) years of commencing this action, exclusive of any applicable tolling <br />periods and those set forth in paragr <br />#h. 13 herein, Defendants, and each of them, have engaged <br />in, and continue to. engage in, unlawful acts, omissions, and practices that constitute unfair <br />competition wig the meaning of Business and Professions Code sections 17200 through 17208, <br />including but not limited to, the acts or omissions and practices alleged in paragraphs 25, 26 and <br />in the First tbroll2h Eleventh Causes of Action, above. Unless enjoined by order of the Court, <br />Defendants, and each of them, may or will continue in the course of conduct as alleged herein. <br />81. Each and every separate act constitutes an unlawful and/or unfair business practice. <br />Each day that Defendants, and each of them, engaged in each separate unlawful act, omission or <br />practice is a separate and distinct violation of Business and Professions Code section 17200. <br />82. Pursuant to Business and Professions Code section 17206, Defendants, and each of <br />them, are liable for civil penalties for each and every separate act of unfair competition as alleged <br />83. Defendants, and each of them, must be immediately and permanently enjoined, <br />pursuant to Business and Professions Code section 17203, from engaging in acts or practices that, <br />as alleged in this Complaint, violate Chapter 6.5 and/or 6.95 of Division 20 of the Health and <br />Safety Code and their implementing regulations, Health and Safety Code section 117600 et seq., <br />and county and local ordinances pertaining to hazardous waste generator permits, which thereby <br />constitute unfair competition within the meaning of Business and Professions Code section <br />17200. <br />/ I / <br />23 <br />First Amended Complaint for Preliminary and Permanent Injunction, Civil Penalties and Other Equitable Relief <br />Case No. RG09457686 <br />