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l MARINA WEST MARINE SERVICES and MARINA WEST MARINE SERVICES, have violated <br /> 2 the law of the State of California by depositing in, permitting to pass into,or placing where it can <br /> 3 pass into waters of the State of California, to wit: Fourteen Mile Slough, a material deleterious to <br /> 4 fish, plant life or bird life, to wit: pressure wash residue containing excessive levels of copper. <br /> 5 THIRD CAUSE OF ACTION <br /> 6 (Violation of Business and Professions Code Sections 17200 et. Seq.) <br /> 7 35. Plaintiff incorporates by reference paragraphs 1 through 34 herein. <br /> 8 36. The People are informed and believe and based upon such information and belief <br /> 9 allege that beginning at a date unknown to the People,but within four years of the date of the filing <br /> 10 of this Complaint, defendants CHRIS McDOUGALL, individually and doing business as MARINA <br /> 11 WEST MARINE SERVICES and MARINA WEST MARINE SERVICES have engaged in acts of <br /> 12 unfair and/or unlawful competition prohibited by California Business and Professions Code sections <br /> 13 17200 - 17208 by virtue of the acts described herein, each of which constitutes an unfair/unlawful <br /> 14 business practice. The unlawful and/or unfair business practices committed by the defendants <br /> 15 include,but are not limited to: <br /> 16 a. Violations of Health and Safety Code sections 25189(c); <br /> 17 b. Violations of Health and Safety Code sections 25189(d); <br /> 18 c. Violations of California Code of Regulations, Title 22 section 66262.11; <br /> 19 d. Violations of California Code of Regulations, Title 22 section 66262.34(f)(3); <br /> 20 e. Violations of California Code of Regulations, Title 22 section 66265.52; <br /> 21 f. Violations of Fish and Game Code section 5650. <br /> 22 PRAYER <br /> 23 WHEREFORE, Plaintiffs pray that: <br /> 24 1. Defendants be permanently restrained and enjoined from engaging in or performing, <br /> 25 directly or indirectly, any and all of hte following acts <br /> 26 a. Violations of Health and Safety Code sections 25189(c); <br /> 27 b. Violations of Health and Safety Code sections 25189(d); <br /> 28 7. <br />