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1 i. Failed to demonstrate the length of time that the universal waste has been <br /> 2 accumulated from the date it becomes a waste or is received, in violation of California Code of <br /> 3 Regulations,title 22 section 66273.15(c). <br /> 4 SECOND CAUSE OF ACTION <br /> 5 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br /> (UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br /> 6 <br /> 16. Paragraphs 1 through 15, above are incorporated herein by reference. Plaintiff is <br /> 7 <br /> informed and believes and based on such information and belief alleges that beginning at an exact <br /> 8 <br /> date that is unknown to Plaintiff,but within five (5)years prior to the filing of this Complaint(CCP <br /> 9 <br /> §338.1), Defendants engaged in acts in violation of Health and Safety Code, section 25280 et seq., <br /> 10 <br /> including but not limited to the following: <br /> 11 <br /> a. Failed to maintain evidence of financial responsibility, in violation of Health and <br /> 12 <br /> Safety Code section 25292.2(a); <br /> 13 <br /> b. Failed to implement a monitoring program approved by the local agency and <br /> 14 <br /> specified in the underground storage tank operating permit, in violation of California Code of <br /> 15 <br /> Regulations,title 23 section 2632(b); <br /> 16 <br /> c. Failed to comply with underground storage tank repair and upgrade requirements, <br /> 17 <br /> in violation of California Code of Regulations,title 23 section 2661. <br /> 18 <br /> THIRD CAUSE OF ACTION <br /> 19 <br /> VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> 20 (UNLAWFUL AND/OR UNFAIR COMPETITION) <br /> 21 17. Paragraphs 1 through 16, above are incorporated herein by reference. Plaintiff is <br /> 22 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 23 date that is unknown to Plaintiff, but within four(4)years prior to the filing of this Complaint(CCP <br /> 24 §338.1), Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br /> 25 Business and Professions Code, section 17200 et seq. by virtue of the acts described herein,each of <br /> 26 which constitutes an unlawful and/or unfair business practice. <br /> 27 14. The use of such unlawful and or unfair business practices constitutes unfair competition <br /> 28 within the meaning of California Business and Professions Code, section 17200 et seq. The unlawful <br /> 5 <br /> VERIFIED COMPLAINT <br />