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1 engaged in the business of waste recycling and transportation <br /> i <br /> 2 with its principal place of business located in the City of <br /> 3 Stockton, County of San Joaquin. <br /> 4 7. Defendant DOES 1 through 5 are connected and responsible <br /> 5 for the acts complained of below. Their real names are unknown <br /> 6 at this time, and the People will amend this complaint at a later <br /> 7 date when the true identities of DOES 1 through 5 are discovered. <br /> 8 <br /> FIRST CAUSE OF ACTION <br /> 9 <br /> VIOLATION OF BUSINESS AND PROFESSIONS <br /> 10 <br /> CODE SECTIONS 17200 - 17208 <br /> 11 <br /> UNLAWFUL AND/OR UNFAIR COMPETITION <br /> 12 <br /> S. Plaintiff is informed and believes and based on such <br /> 13 <br /> information and belief alleges that beginning at an exact date <br /> 14 <br /> 15 that is unknown to plaintiff , but within four (4 ) years prior to <br /> 16 the filing of this complaint, defendants have engaged in acts of <br /> unlawful and/or unfair competition prohibited by California <br /> 17 <br /> Business and Professions Code §17200 - 517208 by virtue of the <br /> 18 <br /> acts described herein, each of which constitutes an unfair and/or <br /> 19 <br /> 20 unlawful business practice. <br /> 9. The unlawful and/or unfair business practices committed <br /> 21 <br /> 22 by defendant include, but are not limited to the following: <br /> 9a. Violation of Penal Code 5374. 3 (a) on or about 12/1/88 in <br /> 23 <br /> that defendants unlawfully dumped coffee grounds in a canal <br /> 24 <br /> 25 waterway located at the 24000 block of South Manteca Road, <br /> 26 Manteca, California . <br /> 27 9b. Operation of a feed lot and silage operation without the <br /> 28 use permit required by San Joaquin County Ordinance Section <br /> 9-4103. <br /> 3 . <br />