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I minimize any potential harm or damage to persons, property, or the environment; <br /> 2 3. Evacuation plans and procedures, including immediate notice, for the <br /> 3 business site; <br /> 4 C. Violation of Health and Safety Code section 25504(c), failed to provide <br /> 5 training for all new employees and annual training, including refresher courses, for all employees in <br /> 6 safety procedures in the event of a release or threatened release of a hazardous material, including, <br /> 7 but not limited to, familiarity with the plans and procedures specified in Health and Safety Code <br /> 8 section 25504(b); <br /> 9 d. Violation of Health and Safety Code section 25505, failed to submit a <br /> 10 business plan for emergency response to a release or threatened release of hazardous material within <br /> 11 four(4) years prior to the filing of this complaint for 1010 INDUSTRIAL DRIVE, STOCKTON, <br /> 12 CALIFORNIA, to the San Joaquin County Office of Emergency Services. Further, it is alleged that <br /> 13 said violation was knowingly committed after reasonable notice; <br /> 14 e. Violation of Health and Safety Code section 25505(e)(2), failed to annually <br /> 15 submit a form, provided by the San Joaquin County Office of Emergency Services, that certifies that <br /> 16 the handler has included, and maintains as current, in the business plan, all other information <br /> 17 required by Health and Safety section 25504. <br /> 18 11. It is further alleged that defendants had reasonable notice of the violations contained <br /> 19 in paragraphs 10 - l Oe above, and that each day of violation thereafter was a knowing violation as <br /> 20 defined in Health and Safety Code section 25514. <br /> 21 THIRD CAUSE OF ACTION <br /> 22 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> 23 (UNFAIR COMPETITION) <br /> 24 12. Paragraphs 1 through 11, above are incorporated herein by reference. Plaintiff is <br /> 25 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 26 date that is unknown to plaintiff, but within four(4) years prior to the filing of this complaint(CCP <br /> 27 §338.1), defendants have engaged in acts of unlawful and/or unfair competition prohibited by <br /> 28 Business and Professions Code section 17200 et seq. by virtue of the acts described herein, each of <br /> Complaint for Injunction, Civil Penalties and Other Relief Page 5 <br />