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a <br />N <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 />I . I <br />§338.1), Defendants engaged in acts in violation of Health and Safety Code §25100 et seq., including <br />by not limited to the following: <br />a. Stored hazardous waste onsite longer than one hundred eighty (180) days, in <br />violation of California Code of Regulations, title 22 section 66262.34(d); and <br />b. Failed to label containers as "drained used oil filters" and show initial date of <br />accumulation or receipt on each container of drained used oil filters, in violation of California Code <br />of Regulations, title 22 section 66266.130(c)(3). <br />!r A II <br />WAIJ Ito W.01,O)KI <br />101 a W.V. NUO M16 MW M ff MIT M-1 I ill�iiiiiiiiiiii 111111111all I I I! I <br />1 '1'' R 1`111 � I' 1111111FO�� <br />informed and believes and based on such information and belief alleges that beginning at an exact <br />date that is unknown to Plaintiff, but within four (4) years prior to the filing of this Complaint (B&P <br />17208�,, Defendants have en d in acts unlawful and/or unfair competition i]irohibited bri Califivitti-a. <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 />11. The use of such unlawful and or unfair business practices constitutes unfair competition <br />I I 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 25280 et seq., as described in <br />I W.M. .7 M- Muanzz.•# <br />b. Violation of Health and Safety Code section 25 100 et seq., as described in <br />I I paragraphs 11--11(b) above. <br />II I Ii! K13 II I ilg 11 Iiii III *CIS C a 11 <br />1. Defendants be permanently restrained and enjoined from engaging in or perforiiiing, <br />I I directly or indirectly, any and all of the following acts: <br />-6— 0 <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER REL <br />