Laserfiche WebLink
1 including but not limited to the following: <br />2 a. Failed to inform the local agency of any changes to the Underground Storage Tank <br />3 Operating Permit Application within thirty (30) days, in violation of California Code of Regulations, <br />4 title 23 section 2711(b); <br />5 b. Failed to file Underground Storage Tank Operating Permit Application - Facility <br />6 Information, Underground Storage Tank Operating Permit Application - Tank Information and <br />7 Underground Storage Tank Monitoring Plan with the local government agency, in violation of <br />8 California Code of Regulations, title 23 section 2711(c). <br />9 THIRD CAUSE OF ACTION <br />10 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br />(UNLAWFUL AND/OR UNFAIR COMPETITION) <br />11 <br />12. Paragraphs 1 through 11, above are incorporated herein by reference. Plaintiff is <br />12 <br />informed and believes and based on such information and belief alleges that beginning at an exact <br />13 <br />date that is unknown to Plaintiff, but within four (4) years prior to the filing of this Complaint (CCP <br />14 <br />§338.1), Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br />15 <br />Business and Professions Code, section 17200 et seq. by virtue of the acts described herein, each of <br />16 <br />which constitutes an unlawful and/or unfair business practice. <br />17 <br />13. The use of such unlawful and or unfair business practices constitutes unfair competition <br />18 <br />within the meaning of California Business and Professions Code, section 17200 et seq. The unlawful <br />19 <br />and/or unfair business practices committed by the Defendants include, but are not limited to: <br />20 <br />a. Violation of Health and Safety Code section 25100 et seq., as described in <br />21 <br />paragraph 10 - l On above; <br />22 <br />b. Violation of Health and Safety Code section 25280 et seq., as described in <br />23 <br />paragraph 11 - 11 b above. <br />24 <br />PRAYER <br />25 <br />WHEREFORE, Plaintiff prays that: <br />26 <br />1. Defendants be permanently restrained and enjoined from engaging in or performing, <br />27 <br />directly or indirectly, any and all of the following acts: <br />28 <br />5 <br />VERIFIED COMPLAINT <br />