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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <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 />`'4 <br />2 <br />26 <br />27 <br />28 <br />g. Failed to maintain a copy of the monthly inspection record and all attachments <br />for the previous twelve (12) months, in violation of California Code of Regulations, title 23 <br />section 2715(e); <br />h. Failed to comply with underground storage tank repair and upgrade <br />requirements, in violation of California Code of Regulations, title 23 section 2661; <br />i. Failed to perform periodic testing of secondary containment system, in <br />violation of California Code of Regulations, title 23 section 2637(a); <br />j. Failed to inform the local agency of any changes to the Underground Storage <br />Tank Operating Permit Application within thirty (30) days, in violation of California Code of <br />Regulations, title 23 section 271 l (b); <br />k. Failed to identify and submit a signed statement to the local agency indicating <br />the designated underground storage tank operator for each facility, in violation of California <br />Code of Regulations, title 23 section 2715(a); and <br />1. Failed to provide training by a designated underground storage tank operator <br />for facility employees on the proper operation and maintenance of the underground storage tank <br />system once every twelve (12) months, in violation of California Code of Regulations, title 23 <br />section 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 />21. Paragraphs 1 through 20, above are incorporated herein by reference. Plaintiff is <br />informed and believes and based on such information and belief alleges that beginning at an <br />exact date that is unknown to Plaintiff, but within four (4) years prior to the filing of this <br />Complaint (CCP §338.1), Defendants have engaged in acts unlawful and/or unfair competition <br />prohibited by California Business and Professions Code, section 17200 et seq. by virtue of the <br />acts described herein, each of which constitutes an unlawful and/or unfair business practice. <br />22. The use of such unlawful and or unfair business practices constitutes unfair <br />II competition within the meaning of California Business and Professions Code, section 17200 et <br />7 <br />VERIFIED COMPLAINT <br />