Laserfiche WebLink
1 including but not limited to the following: <br /> 2 a. Failed to maintain evidence of financial responsibility, in violation of Health and <br /> 3 Safety Code section 25292.2(a); <br /> 4 b. Failed to maintain a copy of the monthly inspection record and all attachments for <br /> 5 the previous twelve months, in violation of California Code of Regulations,title 23 section 2715(e);. <br /> 6 c. Failed to maintain monitoring system for entry of hazardous substance stored in the <br /> 7 primary containment into the secondary containment, in violation Health and Safety Code section <br /> 8 25291(b); <br /> 9 <br /> 10 THIRD CAUSE OF ACTION <br /> 11 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> (UNLAWFUL AND/OR UNFAIR COMPETITION) <br /> 12 <br /> 13 12. Paragraphs 1 through 11, above are incorporated herein by reference. Plaintiff is <br /> 14 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 15 date that is unknown to Plaintiff,but within four(4)years prior to the filing of this Complaint(CCP <br /> 16 17208), Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br /> 17 Business and Professions Code, section 17200 et seq. by virtue of the acts described herein, each of <br /> 18 which constitutes an unlawful and/or unfair business practice. <br /> 19 13. The use of such unlawful and or unfair business practices constitutes unfair competition <br /> 20 within the meaning of California Business and Professions Code, section 17200 et seq. The unlawful <br /> 21 and/or unfair business practices committed by the Defendants include,but are not limited to: <br /> 22 a. Violation of Health and Safety Code section 25100 et seq., as described in <br /> 23 paragraph 10 - I Oe above; <br /> 24 b. Violation of Health and Safety Code section 25280 et seq., as described in <br /> 25 paragraph 11 - l lc above. <br /> 26 /// <br /> 27 /// <br /> 28 /// <br /> 4 <br /> VERIFIED COMPLAINT <br />