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1 leaks and be vapor tight in that vapor check valves were leaking <br /> 2 on November 8, 1985 as set forth in Exhibit 2 at #22 . <br /> 3 FOURTH CAUSE OF ACTION <br /> 4 (UNLAWFUL BUSINESS PRACTICES ) <br /> 5 ACTIONS FOR CIVIL PENALTIES FOR UNLAWFUL BUSINESS <br /> PRACTICES IN VIOLATION OF §§17200-17208 OF THE <br /> 6 BUSINESS AND PROFESSIONS CODE BY VIOLATING THE <br /> HAZARDOUS WASTE CONTROL ACT, THE SAN JOAQUIN COUNTY <br /> 7 AIR POLLUTION CONTROL DISTRICT RULES, AND THE <br /> STOCKTON MUNICIPAL CODE. <br /> 8 <br /> 9 28 . The People reallege and incorporate by reference <br /> 10 paragraphs 1 through 27 . <br /> 11 29 . Plaintiff is informed and believes and therefore alleges <br /> 12 that, beginning on an unknown date, but at least within the three <br /> 13 years prior to the filing of this complaint, and continuing to the <br /> 14 present, defendants, and each of them, have knowingly and <br /> 15 repeatedly engaged in conduct, and continue to engage in conduct <br /> 16 by agents, employees, officers, or directors of ST SERVICES <br /> 17 which is unlawful . Such repeated violations of California law <br /> 18 constitute unfair competition within the meaning of Business and <br /> 19 Professions Code Section 17200 , which, in part , defines unfair <br /> 20 competition as any "unlawful, unfair, or fraudulent business <br /> 21 practice. " Defendants ' acts of unfair competition include, but <br /> 22 are not necessarily limited to, the following: <br /> 23 a ) Violations of the Hazardous Waste Control Act: <br /> 24 <br /> Defendant& committ acts prohibited by the Act <br /> 25 as more particularly alleged in Paragraph 15 and <br /> 26 15a of this complaint, incorporated herein by <br /> 27 reference as if set forth in full herein. <br /> 28 <br /> 13 . <br />