COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

Home Browse Search

I release or threatened release of a hazardous material, in violation of Health and Safety Code section 2 25507(a); and 3 g. Failed to electronically submit a hazardous materials business plan and/or 4 certification annually to the statewide information management system, in violation of Health and 5 Safety Code section 25508(a)(1)(A). 6 THIRD CAUSE OF ACTION 7 VIOLATION OF FISH AND GAME CODE SECTION 5650 ET SEQ. 8 (WATER POLLUTION) 9 17. Paragraphs 1 through 16, above are incorporated herein by reference. Plaintiff is 10 informed and believes and based upon such information and belief alleges that beginning at an exact 11 date that is unknown to Plaintiff,but within three (3)years prior to the filing of this complaint, 12 Defendants have engaged in acts in violation of Fish and Game Code sections 5650 et seq., include 13 but are not limited to the following: 14 a. Allowed a substance or a material which is deleterious to fish,plant life, or bird life 15 to be deposited in,permitted to pass into, or placed where it can pass into the waters of this state, in 16 violation of Fish and Game Code section 5650(a)(6). 17 FOURTH CAUSE OF ACTION 18 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. (UNLAWFUL AND/OR UNFAIR COMPETITION) 19 20 18. Paragraphs 1 through 17, above are incorporated herein by reference. Plaintiff is 21 informed and believes and based on such information and belief alleges that beginning at an exact 22 date that is unknown to Plaintiff,but within four (4)years prior to the filing of this Complaint(B&P 23 17208), Defendants have engaged in acts unlawful and/or unfair competition prohibited by California 24 Business and Professions Code, section 17200 et seq. by virtue of the acts described herein, each of 25 which constitutes an unlawful and/or unfair business practice. 26 19. The use of such unlawful and or unfair business practices constitutes unfair competition 27 within the meaning of California Business and Professions Code, section 17200 et seq. The unlawful 28 and/or unfair business practices committed by the Defendants include, but are not limited to: -6- _'_..�r.-..-.-,.-.