COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

Home Browse Search

I to WASTE OIL, OXYGEN, PETROLEUM NAPTHA and not having established a business plan for 2 emergency response for 1145 SOUTH AURORA ST., STOCKTON, CALIFORNIA. 3 9b. Violation of Health and Safety Code § 25505 by failing to file an emergency business 4 response plan for 1999 and 2000 for 1145 SOUTH AURORA ST., STOCKTON, CALIFORNIA. 5 with the San Joaquin County Office of Emergency Services. Further, it is alleged that said violation 6 was knowingly committed after reasonable notice. 7 10. It is further alleged that defendants had reasonable notice of the violations contained in 8 paragraphs 9a - 9b above on or about January 1, 1999 and January 1, 2000 and that each day of 9 violation thereafter was a knowing violation as defined in Health and Safety Code § 25514. 10 11 SECOND CAUSE OF ACTION 12 VIOLATION OF BUSINESS AND PROFESSIONS 13 CODE SECTIONS 17200 - 17208 14 UNLAWFUL AND/OR UNFAIR COMPETITION 15 11. Plaintiff incorporates by reference paragraphs 1 - 10, above. 16 12. Plaintiff is informed and believes and based on such information and belief allezes that 17 beginning at an exact date that is unknown to plaintiff, but within four(4) years prior to the filing of 18 this complaint, defendants have engaged in acts of unlawful and/or unfair competition prohibited by 19 California Business and Professions Code §17200 - §17208 by virtue of the acts described herein, 20 each of which constitutes an unfair and/or unlawful business practice. These acts include but are not 21 limited to: 22 13. Violation of Health and Safety Code § 25503.5 and § 25505 as further described in the 23 First Cause of Action herein. 24 PRAYER 25 WHEREFORE, Plaintiff prays that: 26 1. Defendants be permanently restrained and enjoined from engaging in or performing, 27 directly or indirectly, any and all of the following acts: 78 3.