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SECOND CAUSE OF ACTION <br /> 1 <br /> VIOLATION OF HEALTH AND SAFETY <br /> 2 <br /> CODE SECTION 25298 <br /> 3 <br /> 4 (UNDERGROUND STORAGE TANKS) <br /> 5 11 . Plaintiff is informed and believes and based on such <br /> 6 information and belief alleges that beginning at an exact date <br /> 7 that is unknown to plaintiff, but within five (5) years (CCP <br /> 8 §338 . 1) prior to the filing of this complaint, defendants have <br /> 9 violated, and aided and abetted the violation of Health and <br /> 10 Safety Code Chapter 6 . 7 , including but not limited to: <br /> 11 lla. Concealment of releases of hazardous substances in <br /> 12 violation of Health and Safety Code §25298 (b) (4) . <br /> 13 llb. Making false representations and/or statements to the <br /> 14 county health department in violation of Health and Safety Code <br /> 15 525299 (a) (8) and (b) (8) . <br /> 16 THIRD CAUSE OF ACTION <br /> 17 VIOLATION OF BUSINESS & PROFESSIONS <br /> 18 CODE SECTION 17200 ET SEQ. <br /> 19 (Unfair/Unlawful Business Practices) <br /> 20 12 . Plaintiff realleges and incorporates by reference as <br /> 21 though set forth in full herein paragraphs 1 through 11, <br /> 22 inclusive. <br /> 23 13 . Plaintiff is informed and believes and therefore <br /> 24 alleges that, beginning on an unknown date, but at least within <br /> 25 the four years prior to the filing of this complaint, and <br /> 26 continuing to the present, defendants have engaged in conduct <br /> 27 which is unlawful . Such violations of California law constitute <br /> 28 <br /> 6 <br />