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1 unfair competition within the meaning of Business and <br /> Professions Code Section 17200, which, in part, defines unfair <br /> 2 <br /> competition as any "unlawful, unfair, or fraudulent business <br /> 3 <br /> practice. " Defendants ' acts of unfair competition include, but <br /> 4 <br /> are not necessarily limited to, the following: <br /> 5 <br /> 13a. Violations of the Hazardous Safety Code, in that <br /> 6 <br /> defendants committed acts more particularly alleged in <br /> 7 <br /> 8 Paragraphs 10 and 11 of this complaint. <br /> 13b. Violation of Penal Code 5182 by conspiring to commit <br /> 9 <br /> 10 acts injurious to the public health by soliciting contracts to <br /> 11 remove underground storage tanks which had contained hazardous <br /> 12 substances and conspiring with the owners and/or operators of <br /> 13 the tanks to conceal the possible presence of hazardous waste <br /> contamination. <br /> 14 <br /> 15 FOURTH CAUSE OF ACTION <br /> 16 NUISANCE <br /> 17 14 . Plaintiff realleges and incorporates by reference as <br /> 18 though set forth in full herein paragraphs 1 through 13 , <br /> 19 inclusive. <br /> 20 15 . As set forth above, defendants have unlawfully <br /> 21 concealed and conspired to permit hazardous waste contamination <br /> 22 -to remain undetected at various locations in San Joaquin County, <br /> 23 California where such contamination constitutes a condition of <br /> 24 pollution and public nuisance, presenting a potential danger to <br /> 25 the public health and safety. <br /> 26 <br /> 27 <br /> 28 <br /> 7 <br />