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f <br />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 />a. Operated gasoline pumps without a permit after January 1, 2003, in <br />violation of Health and Safety Code §25284(a)(1); <br />b. Failure to replace secondary containment system, in violation of 22CCR <br />§2637(a)(1); <br />C. Failure to perform Annual Monitoring' Certification, in violation of <br />22CCR §2637(b); <br />d. Failure to perform Annual Line Tightness Test, in violation of 22CCR <br />§2636(f)(4). <br />SECOND CAUSE OF ACTION <br />VIOLATION OF BUSINESS AND PROFESSIONS CODE <br />SECTIONS 17200 ET SEQ. (UNLAWFUL AND/OR <br />UNFAIR COMPETITION) <br />7. Paragraphs 1 through 6 - 6d, above are incorporated herein by reference. Plaintiff <br />is informed and believes and based on such information and belief alleges that beginning at an <br />exact date that is unknown to plaintiff, but within four (4) years prior to the filing of this <br />complaint, defendants have engaged in acts unlawful and/or unfair competition prohibited by <br />California Business and Professions Code § 17200 § 17208 by virtue of the acts described <br />herein, each of which constitutes an unlawful and/or unfair business practice. <br />8. The use of such unlawful and or unfair business practices constitutes. unfair <br />competition within the meaning of § 17200 of the California Business and Professions Code. The <br />unlawful and/or unfair business practices committed by the defendants include, but are not <br />limited to: <br />a. Violation of Chapter 6.7, of the Health and Safety Code described in <br />paragraph 6 - 6d above. <br />HAHOMMEANTOLMUMBONFARE.WPD 3 <br />