1 consequent social and economic injuries associated with those physical and environmental 2 impacts, which are the causes of Plaintiff’s injuries and damages as described herein. 3 4 5 Plaintiff has already incurred, and will foreseeably continue to incur, injuries and damages because of domoic acid outbreaks caused by Defendants’ conduct. 168. California’s commercial Dungeness crab fishery is seasonal and normally runs for 6 eight months (from November 15 to June 15 south of the Sonoma/Mendocino County line and 7 from December 1 to July 1 north of that line to the California/Oregon border). In Oregon, the 8 season runs from December 1 to August 14 under normal conditions. The early part of crab season 9 is by far the most productive because at that time there are the most crabs on the crab grounds, the 10 crabs’ meat content (the ratio of meat weight to total weight) is at its highest, and the demand for 11 crab spikes around the Thanksgiving, Christmas, New Year and Lunar New Year holidays, and 12 the Super Bowl. 13 169. As a precaution to avoid poisoning humans with domoic acid, the State of 14 California delayed opening the Dungeness crab season at the beginning of the 2015–16 and 2016– 15 17 commercial seasons, and will delay the beginning of the 2018–19 season: 16 a. In 2015–16, the fishery south of the Sonoma/Mendocino County line 17 opened approximately four-and-a-half months late; the fishery north of the 18 Sonoma/Mendocino County line did not fully open until nearly six months 19 after the normal opening date; 20 b. In 2016–17, the fishery opened piecemeal, with a large section of the 21 southern management area and a portion of the northern management area 22 from the Oregon border to Redwood Creek opening on time, and six distinct 23 areas north of Point Reyes in Marin County opening either on time, or with 24 a delay in the range of 18 days to one-and-a-half months. 25 SHER EDLING LLP 167. c. The area from Bodega Head to the Sonoma/Mendocino County line will be 26 closed to commercial crabbing indefinitely; the season will not open as 27 scheduled on November 15, 2018. Sampling farther north has shown that 28 crabs at fishing grounds accessible from ports in Crescent City and COMPLAINT 73