SITE INFORMATION AND CORRESPONDENCE

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I respect to the site locations listed in this complaint as a result of the following: 2 (a) Violating the provisions of Health and Safety Code section 25299.37 by 3 committing the acts noted above in paragraphs 44 through 47. 4 (b) Violating the provisions of Health and Safety Code section 25249.5:et seq. 5 49. These acts comprise a public nuisance as defined by Civil Code section 3480 and present 6 a potential danger to the public health and safety. 7 50. The continued maintenance of this public nuisance will cause irreparable injury to the 8 community and the public at large, and should be enjoined by the Court. 9 IX 10 FOURTH CAUSE OF ACTION 11 (Violation of Health and Safety Code Section 42400 et seq. (Negligent Air Pollution)) 12 51. Plaintiff incorporates by reference herein paragraphs 1 through 50 inclusive, of this 13 complaint. Plaintiff is informed and believes and based on such information and belief alleges 14 that beginning at an exact date that is unknown to plaintiff, but within four(4) years prior to the 15 filing of this complaint, Defendant UNOCAL committed daily violations of Health ans Safety 16 Code section 42400 et seq. at 1665 Pacific Avenue, Stockton, California, including but not 17 limited to: 18 a) Negligently emitted, benzene, an air contaminant. 19 X 20 FIFTH CAUSE OF ACTION 21 (Violation of Business and Professions Code § 17200 - § 17208 22 (Unlawful and/or Unfair Competition)) 23 52. Paragraphs 1 through 51(a) above are incorporated herein by reference. Plaintiff is 24 informed and believes and based on such information and belief alleges that beginning at an 25 exact date that is unknown to plaintiff, but within four(4) years prior to the filing of this 26 complaint, defendants have engaged in daily acts of unlawful and/or unfair competition 27 prohibited by California Business and Professions Code § 17200 - § 17208 by virtue of the acts 28 H:1HONMWYOUNG%CASMUNOCALICOMPLAM.WPD 12