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1 violating the Hazardous Waste Control Act. Said violations <br /> 2 include, but are not limited to, the following: <br /> 3 a. Violations of 5 25201: Treating, storing and/or <br /> 4 disposing of hazardous wastes at 216 S. Center Street, Stockton, <br /> 5 California; without a hazardous waste facilities permit from the <br /> 6 Department of Health Services. <br /> 7 b. Violations of 5 25154 : Operating a facility, to wit: <br /> 8 the facility at 216 S. Center Street, Stockton, California which <br /> 9 generates hazardous waste in violation of applicable laws and <br /> 10 regulations. <br /> 11 C. Violations of 5 25189 . 2 : Disposing or causing the <br /> 12 disposal of a hazardous waste as a point not authorized for said <br /> 13 disposal, to-wit: the dumpster and sanitary sewers at 216 S. <br /> 14 Center Street, Stockton. <br /> 15 <br /> 16 SECOND CAUSE OF ACTION <br /> 17 VIOLATION OF BUSINESS & PROFESSIONS <br /> 18 CODE SECTION 17200 ET SEQ. <br /> 19 (Unfair/Unlawful Business Practices) <br /> 20 12 . Plaintiff realleges and incorporates by reference as <br /> 21 though set forth in full herein paragraphs 1 through 11, <br /> 22 inclusive. <br /> 23 13 . Plaintiff is informed and believes and therefore <br /> 24 alleges that, beginning on an unknown date, but at least within <br /> 25 the four years prior to the filing of this complaint, and <br /> 26 continuing to the present, defendants have engaged in conduct <br /> 27 which is unlawful. Such violations of California law constitute , <br /> 28 unfair competition within the meaning of Business and <br /> 5 <br />