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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 />ii. Defendants, and each of them, violated the <br />provisions of the Fire Code; said acts include but <br />are not limited to the following violations of said <br />provisions: <br />1) Violations of 579.111 in that defendants <br />discharged flammable liquids or any waste: liquid <br />containing petroleum upon the ground in that defen- <br />dants pump oil and water waste that spills at their <br />facility onto the ground of adjacent proper',, (the <br />unlined pond/ lagoon). <br />2) Violation of §79.508(e) in that defen- <br />dants failed to keep a diked area free of com- <br />bustible material in that petroleum product is <br />allowed to stand in unpermitted containers in the <br />diked area. <br />30. Thus, the defendants have in the course of their opera- <br />tion and management of their business engaged in unlawful con- <br />duct. This unlawful conduct of the defendants constitutes unfair <br />competition within the meaning of Business and Professions Code <br />Section 17200 and is conduct which is an unlawful, unfair, and <br />fraudulent business practice. <br />FIFTH CAUSE OF ACTION <br />(NUISANCE) <br />31. Plaintiff realleges and incorporates by reference as <br />though set forth in full herein paragraphs 1 through 30, <br />inclusive. <br />15. <br />