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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11' <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />W" <br />27 <br />California Code of Regulations, title 23 section 2638(a); <br />d. Failed to perform annual line leak detector test, in violation of California Code of <br />Regulations, title 23 section 2638(a); <br />e. Failed to perform annual spill containment testing, in violation of Health and Safety <br />Code Section 25284.2; <br />f. Failed to maintain onsite the monthly reports of the designated operator for the <br />previous twelve (12) months in violation of California Code of Regulations, title 23 section 2715; <br />g. Failed to implement a current monitoring and response program approved by the <br />local agency, in violation of California Code of Regulations, title 23 section 2632(b); <br />h. Failed to have onsite a monitoring and response program approved by local agency <br />in violation of California Code of Regulations, title 23 section 2712(i); <br />i. Failed to maintain onsite the written monitoring and maintenance records for the <br />previous twelve (12) months in violation of California Code of Regulations, title 23 section 2712(b); <br />j. Failed to obtain an operating permit from the local agency in violation of Health <br />and Safety Code Section 25284 <br />THIRD CAUSE OF ACTION <br />VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br />(UNLAWFUL AND/OR UNFAIR COMPETITION) <br />24. Paragraphs 1 through 21, above are incorporated herein by reference. Plaintiff is <br />informed and believes and based on such information and belief alleges that beginning at an exact <br />date that is unknown to Plaintiff, but within four (4) years prior to the filing of this Complaint (CCP <br />§338.1), Defendants have engaged in acts unlawful and/or unfair competition <br />prohibited by California Business and Professions Code, section 17200 et seq. by virtue of the acts <br />described herein, each of which constitutes an unlawful and/or unfair business practice. <br />25. The use of such unlawful and or unfair business practices constitutes unfair competition <br />within the meaning of California Business and Professions Code, section 17200 et seq. The <br />unlawful and/or unfair business practices committed by the Defendants include, but are not limited <br />6 <br />