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4 , <br /> 1 limited to, familiarity with the plans and procedures specified in Health and Safety Code §25504(b); <br /> 2 d. Violation of Health and Safety Code §25505, failed to submit a business plan <br /> 3 for emergency response to a release or threatened release of hazardous material within four(4)years <br /> 4 prior to the filing of this complaint for 515 W. 11THSTREET, TRACY, CALIFORNIA,to the San <br /> 5 Joaquin County Office of Emergency Services. Further, it is alleged that said violation was <br /> 6 knowingly committed after reasonable notice; <br /> 7 e. Violation of Health and Safety Code §25505(e)(2), failed to annually submit a <br /> 8 form,provided by the San Joaquin County Office of Emergency Services, that certifies that the <br /> 9 handler has included, and maintains as current,in the business plan, all other information required by <br /> 10 Health and Safety §25504. <br /> 11 15. It is further alleged that defendants had reasonable notice of the violations contained <br /> 12 in paragraphs 14- Me above, and that each day of violation thereafter was a knowing violation as <br /> 13 defined in Health and Safety Code§25514. <br /> 14 FOURTH CAUSE OF ACTION <br /> 15 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> 16 (UNFAIR COMPETITION) <br /> 17 16. Paragraphs 1 through 15, above are incorporated herein by reference. Plaintiff is <br /> 18 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 19 date that is unknown to plaintiff,but within four(4)years prior to the filing of this complaint(CCP <br /> 20 §338.1),defendants have engaged in acts of unlawful and/or unfair competition prohibited by <br /> 21 Business and Professions Code section 17200 et seq.by virtue of the acts described herein, each of <br /> 22 which constitutes an unfair and/or unlawful business practice. <br /> 23 17. The use of such unlawful and or unfair business practices constitutes unfair <br /> 24 competition within the meaning of section 17200 et seq. of the Business and Professions Code. The <br /> 25 unlawful and/or unfair business practices committed by the defendants include,but are not limited to: <br /> 26 a. Violation of Health and Safety Code section 25280 et seq., as described in paragraph <br /> 27 12—12k above. <br /> 28 b. Violation of Health and Safety Code section 25100 et seq., as described in paragraph <br /> Complaint for Injunction,Civil Penalties and Other Relief Page 6 <br />