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1 knowingly and repeatedly engaged in conduct, and continue to <br /> 2 engage in conduct by agents, employees , officers, or directors <br /> 3 of R.V. CIRCUITS which is unlawful. Such repeated violations of <br /> 4 California law constitute unfair competition within the meaning <br /> 5 of Business and Professions Code Section 17200 , which, in part-; .: <br /> 6 defines unfair competition as any "unlawful, unfair, or fraudu- <br /> 7 lent business practice. " Defendants ' acts of unfair competition <br /> 8 include, but are not necessarily limited to, the following : <br /> 9 a . Violations of the Hazardous Waste Control Act, in that <br /> 10 defendants committed the acts prohibited by the Act as more <br /> 11 particularly alleged in Paragraphs 12 and 13 of this complaint. <br /> 12 PRAYER <br /> 13 WHEREFORE, plaintiff prays judgment as follows : <br /> 14 1 . For a permanent injunction enjoining defendants, and <br /> 15 each of them, and their agents, employees and representatives, <br /> 16 and any and all of them from any unlawful hauling, disposing of, <br /> 17 and storing of any hazardous substance or waste; and requiring <br /> 18 defendants to take all steps necessary to protect public health <br /> 19 and safety. <br /> 20 2 . With respect to the First Cause of Action, for civil <br /> 21 penalties provided by. Health and Safety Code Section 25189 , based <br /> 22 upon violations of the California Hazardous Waste Control Act, <br /> 23 to-wit: Twenty-Five Thousand Dollars ($25 , 000 . 00 ) for each <br /> 24 separate violation, in an amount according to proof but not less <br /> 25 than Two Hundred Thousand Dollars ($200 , 000 . 00 ) . <br /> 26 3 . With respect to the Second Cause of Action, for the <br /> 27 civil penalties provided for by Business and Professions Code <br /> 28 / <br /> 6 . <br />