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I release or threatened release of a hazardous material, in violation of Health and Safety Code section <br /> 2 25507 (a) ; and <br /> 3 g. Failed to electronically submit a hazardous materials business plan and/or <br /> 4 certification annually to the statewide information management system, in violation of Health and <br /> 5 Safety Code section 25508 (a) ( 1 ) (A) . <br /> 6 <br /> THIRD CAUSE OF ACTION <br /> 7 VIOLATION OF FISH AND GAME CODE SECTION 5650 ET SEQ . <br /> 8 (WATER POLLUTION) <br /> 9 17 . Paragraphs 1 through 16 , above are incorporated herein by reference . Plaintiff is <br /> 10 informed and believes and based upon such information and belief alleges that beginning at an exact <br /> 11 date that is unknown to Plaintiff, but within three (3 ) years prior to the filing of this complaint, <br /> 12 Defendants have engaged in acts in violation of Fish and Game Code sections 5650 et seq. , include <br /> 13 but are not limited to the following : <br /> 14 a. Allowed a substance or a material which is deleterious to fish, plant life, or bird life <br /> 15 to be deposited in, permitted to pass into, or placed where it can pass into the waters of this state, in <br /> 16 violation of Fish and Game Code section 5650 (a) (6) . <br /> 17 FOURTH CAUSE OF ACTION <br /> 18 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> (UNLAWFUL AND/OR UNFAIR COMPETITION) <br /> 19 <br /> 20 18 . Paragraphs 1 through 17, above are incorporated herein by reference . Plaintiff is <br /> 21 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 22 date that is unknown to Plaintiff, but within four (4) years prior to the filing of this Complaint (B &P <br /> 23 17208), Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br /> 24 Business and Professions Code, section 17200 et seq. by virtue of the acts described herein, each of <br /> 25 which constitutes an unlawful and/or unfair business practice . <br /> 26 19 . The use of such unlawful and or unfair business practices constitutes unfair competition <br /> 27 within the meaning of California Business and Professions Code, section 17200 et seq. The unlawful <br /> 28 <br /> and/or unfair business practices committed by the Defendants include, but are not limited to : <br /> - 6 - <br /> _ '_..� r.-.- 7rr Tl. Y � T nTT TTY TNT7 . T AT mm0 A / %TTTT7) nrT TUT' <br />