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i <br /> 1 16. Business and Professions Code section 17206 imposes civil liability for any act of <br /> 2 unfair competition, as defined in California Business and Professions Code section 17200. <br /> 3 17. Business and Professions Code section 17203 authorizes the Court to issue an <br /> 4 order that enjoins any person who engages,has engaged, or proposes to engage in unfair <br /> 5 competition, as defined in California Business and Professions Code section 17200. <br /> 6 18. Health and Safety Code sections 25181 and 25184 authorize the Court to issue an <br /> 7 order that enjoins any ongoing or potential violation of the HWCL, or of any applicable rule, <br /> 8 regulation,permit, standard,requirement, or order issued or promulgated pursuant to the HWCL. <br /> 9 19. Health and Safety Code sections 25516 and 25516.1 authorize the Court to issue <br /> 10 an order that enjoins any ongoing or potential violation of Chapter 6.95. <br /> 11 20. Health and Safety Code sections 25184 and 25516.2 provide that in civil actions <br /> 12 brought pursuant to the HWCL or Chapter 6.95, respectively, in which an injunction or temporary <br /> 13 restraining order is sought, it shall not be necessary for the People to allege or prove at any stage <br /> 14 of the proceeding that irreparable damage will occur should the temporary restraining order, <br /> 15 preliminary injunction, or permanent injunction not be issued, or that the remedy at law is <br /> 16 inadequate, and the temporary restraining order,preliminary injunction, or permanent injunction <br /> 17 shall issue without such allegations and without such proof. <br /> 18 GENERAL ALLEGATIONS <br /> 19 The People are informed and believe and based thereon allege as follows: <br /> 20 21. At all times relevant hereto and continuing from and after the date of filing of this <br /> 21 Complaint,Defendant owned or operated and continues to own or operate, and is responsible for <br /> 22 acts and/or omissions committed at,Defendant's Facilities throughout California. At all times <br /> 23 relevant hereto and continuing from and after the date of filing of this Complaint, Defendant <br /> 24 handled at Defendant's Facilities significant quantities of hazardous materials, including but not <br /> 25 limited to,pharmaceuticals and over-the-counter medications, bleaches,photoprocessing <br /> 26 chemicals,pool chlorine and acids, batteries, electronic devices,mercury-containing lamps, <br /> 27 ignitable liquids, aerosol products, oven cleaners and various other cleaning agents,automotive <br /> 28 products, and other flammable, reactive, toxic and corrosive materials. Most of those hazardous <br /> 6 <br /> Complaint For Permanent Injunction,Civil Penalties And Other Equitable Relief <br /> I <br />