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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />91 <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 />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 (CCP <br />§338.1), Defendants have engaged in acts unlawful and/or unfair competition prohibited by <br />California Business and Professions Code, section 17200 et seq. by virtue of the acts described <br />herein, each of which constitutes an unlawful and/or unfair business practice. <br />12. 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 <br />unlawful and/or unfair business practices committed by the Defendants include, but are not limited <br />to: <br />a. Violation of Health and Safety Code section 25100 et seq., as described in <br />paragraph 9 - 9e above; <br />b. Violation of Health and Safety Code section 25280 et seq., as described in <br />paragraph 10 - 10j above. <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 25100 et seq., <br />including but not limited to: <br />1. Violation of Health and Safety Code section 25160.2(b)(3); <br />2. Violation of Health and Safety Code section 25187.8(b); <br />3. Violation of California Code of Regulations, title 22 section 66261.7(f ; <br />4. Violation of California Code of Regulations, title 22 section 66262.11; <br />5. Violation of California Code of Regulations, title 22 section 66262.40(a); <br />b. Engaging in any acts in violation of Health and Safety Code, section 25280 et seq., <br />including but not limited to: <br />1. Violation of Health and Safety Code section 25284.2; <br />5 <br />VERI1FIED COMPLAINT <br />