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1 SECOND CAUSE OF ACTION <br /> 2 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> (UNLAWFULAND/OR UNFAIR COMPETITION) <br /> 3 <br /> 4 8. Paragraphs 1 through 7,above are incorporated herein by reference. Plaintiff is informed <br /> 5 and believes and based on such information and belief alleges that beginning at an exact date that is <br /> 6 unknown to Plaintiff,but within four(4)years prior to the filing of this Complaint( P section <br /> 7 17208),Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br /> g Business and Professions Code,section 17200 et seq.by virtue of the acts described herein,each of <br /> 9 which constitutes an unlawful and/or unfair business practice. <br /> 10 9. The use of such unlawful and or unfair business practices constitutes unfair competition <br /> 11 within the meaning of California Business and Professions Code, section 17200 et seq. The unlawful <br /> 12 and/or unfair business practices committed by the Defendants include, but are not limited to: <br /> 13 a. Violation of Health and Safety Code 25299(a)(9). <br /> 14 PRAYER <br /> 15 WHEREFORE, Plaintiff prays that: <br /> 16 1. Defendants be permanently restrained and enjoined from engaging in or performing, <br /> 17 directly or indirectly,any and all of the following acts: <br /> 18 a. Engaging in any acts in violation of Health and Safety Code §25280 et seq. <br /> 19 including but not limited to: <br /> 20 1. Violation of Health and.Safety Code section 25299(a)(9). <br /> 21 c. Engaging in any of the unlawful acts of unfair competition set forth in the Second <br /> 22 Cause of Action of this Complaint,as well as any other violations of the Business and Professions <br /> 23 Code, section 17200 et seq.,including but not limited to: <br /> 24 1. Violation of Health and Safety Code section 25299(a)(9). <br /> 25 2. For violation of the First Cause of Action,that Defendants herein be assessed a civil <br /> 26 penalty of not less than FIVE HUNDRED DOLLARS ($500.00)or more than FIVE THOUSAND <br /> 27 DOLLARS ($5,000.00)for each underground storage tank system for each day of violation of Health <br /> 28 and Safety Code 25280 et seq.,in an amount according to proof,pursuant to Health and Safety Code <br /> -3- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />