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1 <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 />16 <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 />designated underground storage tank operator for each facility, in violation of California Code of <br />Regulations, title 23 section 2715(a); and <br />1. Failed to provide training by a designated underground storage tank operator for <br />facility employees on the proper operation and maintenance of the underground storage tank system <br />once every twelve (12) months, in violation of California Code of Regulations, title 23 section <br />2715(f); <br />THIRD CAUSE OF ACTION <br />VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br />(UNLAWFUL AND/OR UNFAIR COMPETITION) <br />9. Paragraphs 1 through 8, above are incorporated herein by reference. Plaintiff is informed <br />and believes and based on such information and belief alleges that beginning at an exact date that is <br />unknown to Plaintiff, but within four (4) years prior to the filing of this Complaint (CCP §338.1), <br />Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br />Business and Professions Code, section 17200 et seq. by virtue of the acts described herein, each of <br />which constitutes an unlawful and/or unfair business practice. <br />10. The use of such unlawful and or unfair business practices constitutes unfair competition <br />within the meaning of California Business and Professions Code, section 17200 et seq. The unlawful <br />and/or unfair business practices committed by the Defendants include, but are not limited to: <br />a. Violation of Health and Safety Code section 25100 et seq., as described in <br />paragraph 7 - 7j above; <br />b. Violation of Health and Safety Code section 25280 et seq., as described in <br />paragraph 8 - 81 above. <br />PRAYER <br />WHEREFORE, Plaintiff prays that: <br />1. Defendants be permanently restrained and enjoined from engaging in or performing, <br />directly or indirectly, any and all of the following acts: <br />a. Engaging in any acts in violation of Health and Safety Code section 25100 et seq., <br />including but not limited to: <br />1. Violation of California Code of Regulations, title 22 section 66265.31; <br />-5- <br />FIRST AMENDED VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />