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I explosion, or any unplanned sudden or non-sudden release of hazardous waste,in violation of <br /> 2 California Code of Regulations,title 22 section 66265.31; <br /> 3 q. Failed to equip the facility with portable extinguishers, fire control equipment, spill <br /> 4 control equipment and/or decontamination equipment,in violation of California Code of <br /> 5 Regulations, title 22 section 66265.32(c); <br /> 6 r. Failed to keep a record of each shipment of universal waste sent from the universal <br /> 7 waste handler's facility to another facility, in violation of California Code of Regulations,title 22 <br /> 8 section 66273.39(e); and <br /> 9 s. Failed to submit a written response relating to the received inspection report to the <br /> 10 authorized local agency within the required timeframe, in violation of Health.and Safety Code <br /> 1.1 section 25185(c)(3). <br /> THIRD CAUSE OF ACTION <br /> 12 <br /> VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> 13 (UNLAWFUL AND/OR UNFAIR COMPETITION) <br /> 14 13. Paragraphs 1 through 12, above are incorporated herein by reference. Plaintiff is <br /> 15 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 16 date that is unknown to Plaintiff,but within four(4) years prior to the filing of this Complaint(B&P <br /> 17 1.7208),Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br /> 18 Business and Professions Code, section 17200 et seq. by virtue of the acts described herein,each of <br /> 19 which constitutes an unlawful and/or unfair business practice. <br /> 20 14. The use of such unlawful and or unfair business practices constitutes unfair competition <br /> 21 within the meaning of California Business and Professions Code, section 17200 et seq. The unlawful <br /> 22 and/or unfair business practices committed by the Defendants include,but are not limited to: <br /> 23 a. Violation of Health and Safety Code section 25280 et seq.,as described in <br /> 24 paragraphs 11 — 11(s)above; <br /> 25 b. Violation of Health and Safety Code section 25100 et seq., as described in <br /> 26 paragraphs 12— 12(s)above. <br /> 27 PRAYER <br /> 28 WHEREFORE,Plaintiff prays that: <br /> -7- <br /> ......_._......._..._...-..._................................................_................ __. ___ _ _.......................... <br /> ....:.::_ <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />