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