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3 I described herein, each of which constitutes an unlawful and/or unfair business practice. 2 53. The use of such unlawful and/or unfair business practices constitutes unfair competition 3 with the meaning of§ 17200 of the California Business and Professions Code. The unlawful 4 and/or unfair business practices committed by defendants include, but are not limited to: 5 53(a). Violations of Chapter 6.7 of the California Health and Safety Code described in 6 paragraphs 43 through 43(1), above; 7 53(b). Violations of Chapter 6.75 of the California Health and Safety Code described in 8 paragraphs 44 through 47, above; 9 53(c) Violations of the Health and Safety Code related to negligent air pollution. 10 53(d) Violations of the California Water Code, related to unauthorized releases. 11 53(e) Violations of the California Fish and Game Code, as it relates to off property discharges 12 of petroleum products. 13 53(f)Violations of San Joaquin County Ordinance Section 9-1115.3, well permitting 14 requirements. 15 16 PRAYER 17 WHEREFORE, Plaintiff prays that: 18 1. Defendants be permanently restrained and enjoined from engaging in or 19 performing, directly or indirectly, any and all of the following acts: 20 (a) Engaging in any acts of unfair competition set forth in paragraphs 47 through 21 50, inclusive, of the Second Cause of Action of this complaint, pursuant to Business and 22 Professions Code §17203. 23 (b) Engaging in any acts of violation of Chapter 6.7 of the Health and Safety 24 Code and to take such action as required by that Chapter. 25 (c) Engaging in any acts of violation of Chapter 6.75 of the Health and Safety 26 Code and to take such action as required by that Chapter. 27 2. Defendants herein be assessed a civil penalty of FIVE THOUSAND DOLLARS 28 ($5,000.00) per day per underground storage tank for each violation of Health and Safety Code H:\HOMEMYOUNGICASESNUHOCALkCOMPLAIN.WPD 13