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1 <br /> 1 14. The use of such unlawful and or unfair business practices constitutes unfair competition <br /> 2 within the meaning of California Business and Professions Code,section 17200 et seq. The unlawful <br /> 3 and/or unfair business practices committed by the Defendants include,but are not limited to: <br /> 4 a.Violation of Health and Safety Code section 25280 et seq., as described in <br /> 5 paragraphs 12 - 12(k)above. <br /> 6 PRAYER <br /> 7 WHEREFORE,Plaintiff prays that: <br /> 8 1. Defendants be permanently restrained and enjoined from engaging in or performing, <br /> 9 directly or indirectly, any and all of the following acts: <br /> 10 a.Engaging in any acts in violation of Health and Safety Code section 25280 et seq., <br /> 1 1 including but not limited to: <br /> 12 1. Violation of Health and Safety Code section 25291(b); <br /> 13 2. Violation Health and Safety Code section 25291(e); <br /> 14 3. Violation of Health and Safety Code section 25292.2(a); <br /> 15 4. Violation of California Code of Regulations,title 23 section 2636(c)(1); <br /> 16 5. Violation of California Code of Regulations,title 23 section 2636(f)(2); <br /> 17 6. Violation of California Code of Regulations,title 23 section 2637(a); <br /> l 5 7. Violation of California Code of Regulations,title 23 section 2638(d); <br /> 19 8. Violation of California Code of Regulations,title 23 section 2712(b); <br /> 20 9. Violation of California Code of Regulations,title 23 section 2715(c)(1); <br /> l 10. Violation of California Code of Regulations,title 23 section 2715(c)(5); <br /> 22 and <br /> 23 11. Violation of California Code of Regulations,title 23 section 2715(e). <br /> 24 b.Engaging in any of the unlawful acts of unfair competition set forth in the Second <br /> 25 Cause of Action of this Complaint,as well as any other violations of the Business and Professions <br /> 26 Code, sectionl7200 et seq.,including but not limited to: <br /> 27 1. Violation of Health and Safety Code section 25280 et seq.,as described i» <br /> 28 paragraphs 12- 12(k)above. <br /> -5- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />