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1 Violation of California Code of Regulations, Title 22 §66265.52, failed to <br /> 2 complete conti ency plan. <br /> 3 <br /> 4 SECOND CAUSE OF ACTION <br /> 5 VIOLATION OF BUSINESS AND PROFESSIONS <br /> 6 CODE SECTIONS 17200 - 17208 <br /> 7 UNLAWFUL AND/OR UNFAIR COMPETITION <br /> 8 11. Plaintiff incorporates by reference paragraphs 1 - 10, above. <br /> 9 12. Plaintiff is informed and believes and based on such information and belief alleges <br /> 10 that beginning a an exact date that is unknown to plaintiff, but within four (4) years prior to the <br /> 11 filing of this complaint, defendants have engaged in acts of unlawful and/or unfair competition <br /> 12 prohibited by California Business and Professions Code §17200 - §17208 by virtue of the acts <br /> 13 described herein, each of which constitutes an unfair and/or unlawful business practice. These acts <br /> 14 include but not limited to: <br /> 15 a Violation of Chapter 6.5, of the Health and Safety Code described in <br /> 16 paragraph 10 above. <br /> 17 <br /> 18 PRAYER <br /> 19 WHERE ORE, Plaintiff prays that: <br /> 20 1. fendants be permanently restrained and enjoined from engaging in or performing, <br /> 21 directly or indire tly, any and all of the following acts: <br /> 22 a. Engaging in any acts in violation of Chapter 6.5, of the Health and Safety <br /> 23 Code, including ut not limited to: <br /> 24 1. Violation of Health and Safety Code §25189.5. <br /> 25 2. Violation of Health and Safety Code §25201(a). <br /> 26 3. Violation of California Code of Regulations, Title 22 §66262.11. <br /> 27 4. Violation of California Code of Regulations, Title 22 §66265.32. <br /> 28 4. <br />