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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 />24 <br />25 <br />26 <br />27 <br />28 <br />10. Violation of California Code of Regulations, title 22 section <br />66266.8 1 (a)(4)(B). <br />b. Engaging in any acts in violation of Health and Safety Code, section 25280 et <br />seq., including but not limited to: <br />1. Violation of California Code of Regulations, title 23 section 2712(b); <br />2. Violation of Health and Safety Code section 25292.2; <br />3. Violation of California Code of Regulations, title 23 section <br />2636(c)(1); <br />4. Violation of California Code of Regulations, title 23 section 2632(b); <br />5. Violation of Health and Safety Code Section 25291(b); <br />6. Violation of California Code of Regulations, title 23 section 2715(c); <br />7. Violation of California Code of Regulations, title 23 section 2715(e); <br />8. Violation of California Code of Regulations, title 23 section 2661; <br />9. Violation of California Code of Regulations, title 23 section 2637(a); <br />10. Violation of California Code of Regulations, title 23 section 2711(b); <br />11. Violation of California Code of Regulations, title 23 section 2715(a); <br />I and <br />12. Violation of California Code of Regulations, title 23 section 2715(f); <br />c. Engaging in any of the unlawful acts of unfair competition set forth in the <br />Third Cause of Action of this Complaint, as well as any other violations of the Business and <br />Professions Code, section 17200 et seq., including but not limited to: <br />1. Violation of Health and Safety Code section 25100 et seq., as described <br />in paragraph 19 - 19j above; <br />2. Violation of Health and Safety Code section 25280 et seq., as described <br />in paragraph 20 - 201 above; <br />2. For violation of First Cause of Action, that Defendants herein be assessed a civil <br />penalty of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an <br />amount according to proof, pursuant to Health and Safety Code section 25198.2; <br />I <br />VERIFIED COMPLAINT <br />