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1 72. The Fact Sheet falsely implies that the RWQCB is investigating Lima Ranch b <br /> 2 requesting Lima Ranch's neighbors "To assist the Water Board ... to act quickly in response t <br /> 3 the contamination" by providing information to Ms. Herbst, Unit Chief, and Ms. Creedon <br /> 4 Executive Officer, of the RWQCB and providing contact information for both Ms. Herbst an <br /> 5 Ms. Creedon. The RWQCB is not investigating Lima Ranch. <br /> 6 73. Finally, the Fact Sheet misleadingly accuses Lima Ranch of creating a sever <br /> 7 health hazard by stating that data shows that the levels of nitrogen in the groundwater is a <br /> 8 "levels more that 10 times the California Maximum Contaminant Level (MCL) established <br /> 9 by the Department of Health Services" and that "[t]he MCL is the amount of nitrate that, i <br /> 10 exceeded may cause adverse health affects [sic]." (Emphasis in Original.) <br /> 11 74. The MCL established by the California Department of Health Services only <br /> 12 establishes a level that is safe for drinking water. 22 CCR § 63341. The Fact Sheet misleading) <br /> 13 asserts that exceeding the MCL alone can cause adverse health effects without clarifying that i <br /> 14 will only have such effects if the water is consumed or ingested. <br /> 15 75. These statements were published to third parties including, but not limited t <br /> 16 Plaintiffs' neighbors. <br /> 17 76. It is clear on the face of the document that the false and misleading statement <br /> 18 were made about Lima Ranch. <br /> 19 77. On information and belief, these third parties understood these statements to b <br /> 20 about Lima Ranch, Jack Hamm, and Patricia Hamm. <br /> 21 78. On information and belief, these third parties understood that the statement <br /> 22 meant that Lima Ranch was operating in an unlawful manner so as to cause severe pollution iri <br /> 23 the region which could have severe adverse health effects. On information and belief, these third <br /> 24 parties may interpret the statements to mean that Lima Ranch was being investigated by the <br /> 25 RWQCB, as Mr. Alegre understood the statements to mean Lima Ranch was being investigate <br /> 26 by the RWQCB. <br /> 27 <br /> 28 <br /> HERUM`.CRABI REE <br /> 14 <br /> COMPLAINT FOR TEMPORARY RESTRAINING ORDER,PRELIMINARY AND PERMANENT <br /> INJUNCTION,LIBEL PER SE, AND LIBEL PER QUOD <br />