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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 />26 <br />27 <br />28 <br />10. Paragraphs 1 through 9, 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 prohibited by California <br />Business and Professions Code, section 17200 et seq. by virtue of the acts described herein, each of <br />which constitutes an unlawful and/or unfair business practice. <br />11. 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 />Violation of Health and Safety Code section 25280 et seq., as described in <br />paragraphs 8 - 8(n) above; <br />Violation of Health and Safety Code section 25100 et seq., as described in <br />paragraphs 9 - 9(m) above. <br />PRAYER <br />WHEREFORE, Plaintiff prays that: <br />1. Defendants be permanently restrained and enjoined from engaging in or performing, <br />directly or indirectly, any and all of the following acts: <br />a. Engaging in any acts in violation of Health and Safety Code section 25280 et seq., <br />including but not limited to: <br />Violation of Health and Safety Code section 25290.1(c)(1); <br />Violation of Health and Safety Code section 25290.1(c)(2); <br />Violation of Health and Safety Code section 25290.1(c)(3) <br />Violation of Health and Safety Code section 25290.1(e); <br />Violation of California Code of Regulations, title 23 section 2715(b); <br />Violation of California Code of Regulations, title 23 section 2715(c)(1); <br />Violation of Health and Safety Code section 25284(a)(1); <br />Violation of California Code of Regulations, title 23 section 2712(i); <br />Violation of California Code of Regulations, title 23 section 2712(b); <br />- 6 - <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF