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1 THIRD CAUSE OF ACTION <br /> 2 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> (UNLAWFUL AND/OR UNFAIR COMPETITION) <br /> 3 <br /> 10. Paragraphs 1 through 9, above are incorporated herein by reference. Plaintiff is informed <br /> 4 <br /> and believes and based on such information and belief alleges that beginning at an exact date that is <br /> 5 <br /> unknown to Plaintiff, but within four(4) years prior to the filing of this Complaint(B&P §17208), <br /> 6 <br /> Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br /> 7 <br /> Business and Professions Code, sections 17200 et seq. by virtue of the acts described herein, each of <br /> 8 <br /> which constitutes an unlawful and/or unfair business practice. The use of such unlawful and or <br /> 9 <br /> unfair business practices constitutes unfair competition within the meaning of California Business <br /> 10 <br /> and Professions Code, section 17200 et seq. The unlawful and/or unfair business practices <br /> 11 <br /> committed by the Defendants include,but are not limited to: <br /> 12 <br /> a. Violation of Health and Safety Code sections 25100 et seq., as described in <br /> 13 <br /> paragraphs 8 —8(d) above; and <br /> 14 <br /> b. Violation of Health and Safety Code sections 25500 et seq., as described in <br /> 15 <br /> paragraphs 9—9(c) above. <br /> 16 <br /> PRAYER <br /> 17 <br /> WHEREFORE,Plaintiff prays that: <br /> 18 <br /> 1. Defendants be permanently restrained and enjoined from engaging in or performing, <br /> 19 <br /> directly or indirectly, any and all of the following acts: <br /> 20 <br /> a. Engaging in any acts in violation of Health and Safety Code section 25100 et seq., <br /> 21 <br /> including but not limited to: <br /> 22 <br /> 1. Violation of California Code of Regulations,title 22 section <br /> 23 <br /> 66262.34(d)(2); <br /> 24 <br /> 2. Violation of California Code of Regulations,title 22 section 66262.40(a); <br /> 25 <br /> 3. Violation of California Code of Regulations, title 22 section 66262.42(c); <br /> 26 <br /> and <br /> 27 <br /> 4. Violation of Health and Safety Code section 25160.2(b)(3). <br /> 28 <br /> -4- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />