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1 designated underground storage tank operator for each facility,in violation of California Code of <br /> 2 Regulations,title 23 section 2715(a); <br /> 3 1. Failed to record results of each inspection by the designated underground storage <br /> 4 tank operator in a monthly inspection report, in violation of California Code of Regulations,title 23 <br /> 5 section 2715(c); <br /> 6 m. Failed to maintain a copy of the monthly inspection record and all attachments for <br /> 7 the previous twelve months, in violation of California Code of Regulations,title 23 section 2715(e). <br /> 8 THIRD CAUSE OF ACTION <br /> 9 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> 10 (UNLAWFUL AND/OR UNFAIR COMPETITION) <br /> 11 13. Paragraphs 1 through 12,above are incorporated herein by reference. Plaintiff is <br /> 12 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 13 date that is unknown to Plaintiff, but within four(4)years prior to the filing of this Complaint(CCP <br /> 14 §338.1),Defendants have engaged in acts unlawful and/or unfair competition prohibited by <br /> 15 California Business and Professions Code, section 17200 et seq. by virtue of the acts described <br /> 16 herein, each of which constitutes an unlawful and/or unfair business practice. <br /> 17 14. The use of such unlawful and or unfair business practices constitutes unfair competition <br /> 18 within the meaning of California Business and Professions Code,section 17200 et seq. The <br /> 19 unlawful and/or unfair business practices committed by the Defendants include,but are not limited <br /> to: <br /> 20 <br /> 21 a. Violation of Health and Safety Code section 25100 et seq., as described in <br /> 22 paragraph 10- 10e above; <br /> 23 b. Violation of Health and Safety Code section 25280 et seq.,as described in <br /> 24 paragraph 11 - 11 m above. <br /> 25 PRAYER <br /> 26 WHEREFORE, Plaintiff prays that: <br /> 27 1. Defendants be permanently restrained and enjoined from engaging in or performing, <br /> 28 5 <br /> VERIFIED COMPLAINT <br />