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I d. Violation of Health and Safety Code section 25505,by failing to submit a complete <br /> 2 and accurate business plan for emergency response to a release or threatened release of <br /> 3 hazardous material for each of the Covered Facilities, to the administering agency. Further, it is <br /> 4 alleged that said violation was knowingly committed after reasonable notice; <br /> 5 e. Violation of Health and Safety Code section 25505(e)(2), by failing to annually <br /> 6 submit a form that certifies that the handler has included, and maintains as current, in the <br /> 7 business plan, all other information required by Health and Safety section 25504. <br /> 8 f, Violation of Health and Safety Code section 25504,by failing to provide adequate <br /> 9 training of all employees to respond to a hazardous material spill or release, including the failure <br /> 10 to familiarize employees with the monitoring plan and release report procedures in the business <br /> 11 response plan. <br /> 12 FIRST CAUSE OF ACTION <br /> 13 VIOLATION OF HEALTH AND SAFETY CODE §25500 ET SEQ. <br /> (HAZARDOUS MATERIALS RELEASE RESPONSE PLANS AND INVENTORY) <br /> 14 <br /> 15 9. Plaintiff realleges Paragraphs 1 through 8, inclusive. <br /> 16 10. Pursuant to Health and Safety Code section 25516, a district attorney or city <br /> 17 attorney, at the request of an administering agency within the prosecuting agency's jurisdiction, <br /> 18 or on the district attorney's or city attorney's own motion,may apply to the superior court for an <br /> 19 order directing compliance with Chapter 6.95. <br /> 20 11. The Attorney General and the District Attorney are authorized to bring this cause of <br /> 21 action pursuant to California Health and Safety Code section 25516.1. <br /> 22 12. GMRI is liable for civil penalties pursuant to California Health and Safety Code <br /> 23 section 25514 for each violation of the California Health and Safety Code as set forth in <br /> 24 paragraphs 8 - 8f above. <br /> 25 13. GMRI must immediately and permanently be enjoined from further violations of <br /> 26 Chapter 6.95 of the California Health and Safety Code. <br /> 27 /// <br /> 28 /// <br /> a <br /> rn1 J.AMTWnW C1VII.PFNAI.TIFQ AND TN.RTN('rFVF.RRT,TRV <br />