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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 />26 <br />27 <br />28 <br />i. Failed to record results of each inspection by the designated underground storage <br />tank operator in a monthly inspection report, in violation of California Code of Regulations, title 23 <br />section 2715(c); <br />j. Failed to retain a copy of each monthly visual inspection by the designated <br />underground storage tank operator stating any conditions discovered and follow-up actions, in <br />violation of California Code of Regulations, title 23 section 2715(d); <br />k. Failed to perform annual spill containment testing, in violation of Health and <br />Safety Code Section 25284.2; <br />1. 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 />m. Failed to properly locate monitoring equipment to detect a leak in the underground <br />storage tank system in violation of California Code of Regulations, title 23 section 2630(d). <br />THIRD CAUSE OF ACTION <br />VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br />(UNLAWFUL AND/OR UNFAIR COMPETITION) <br />12. Paragraphs 1 through 11, 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 (B&P <br />17208), 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 />13. 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 unlawful <br />and/or unfair business practices committed by the Defendants include, but are not limited to: <br />a. Violation of Health and Safety Code section 25100 et seq., as described in <br />paragraphs 10 -10(i) above; and <br />b. Violation of Health and Safety Code section 25280 et seq., as described in <br />5 <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />