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2 <br />3 <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 />previous twelve months, in violation of California Code of Regulations, title 23 section 2715(e); <br />p. Failed to provide training by a designated underground storage tank operator for facility <br />every twelve (12) months, in violation of California Code of Regulation, title 23 section 2715(�. <br />SECOND CAUSE OF ACTION <br />VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br />(UNLAWFUL AND/OR UNFAIR COMPETITION) <br />13. Paragraphs 1 through 12, 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 pnknown 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 />14. 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 />arid/or unfair business practices committed by the Defendants include, but are not limited to: <br />a. Violation of Health and Safety Code section 25280 et seq., as described in <br />paragraphs 12 —12(p) 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 25280 et seq., <br />including but not limited to: <br />1. Violation of Health and Safety Code section 25284.2; <br />2. Violation of Health and Safety Code section 25291(b); <br />3. Violation of Health and Safety Code section 25291(f); <br />4. Violation of Health and Safety Code section 25292.2(a); <br />WR TF IED C CIVIL PENAMES, AND OWER UjT.�-_F <br />