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I 9b. Violation of Health and Safety Code § 25505 by failing to file an emergency business 2 response plan for 1998 for 1145 SOUTH AURORA ST., STOCKTON, CALIFORNIA. with the San 3 Joaquin County Office of Emergency Services. Further, it is alleged that said violation was 4 knowingly committed after reasonable notice. 5 10. It is further alleged that defendants had reasonable notice of the violations contained in 6 paragraphs 9a- 9b above on or about January 1, 1998 and that each day of violation thereafter was a 7 knowing violation as defined in Health and Safety Code § 25514. 8 SECOND CAUSE OF ACTION 9 VIOLATION OF BUSINESS AND PROFESSIONS 10 CODE SECTIONS 17200 - 17208 11 UNLAWFUL AND/OR UNFAIR COMPETITION 12 11. Plaintiff incorporates by reference paragraphs 1 - 10, above. 13 12. Plaintiff is informed and believes and based on such information and belief alleges that 14 beginning at an exact date that is unknown to plaintiff, but within four (4)years prior to the filing of 15 this complaint, defendants have engaged in acts of unlawful and/or unfair competition prohibited by 16 California Business and Professions Code §17200 - §17208 by virtue of the acts described herein, 17 each of which constitutes an unfair and/or unlawful business practice. These acts include but are not 18 limited to: 19 13. Violation of Health and Safety Code § 25503.5 and 20 § 25505 as further described in the First Cause of Action herein. 21 PRAYER 2� WHEREFORE, Plaintiff prays that: 23 1. Defendants be permanently restrained and enjoined from engaging in or performing, 24 directly or indirectly, any and all of the following acts: 25 (a) Engaging in any of the unlawful acts of unfair competition set forth in the First 26 and Second Cause of Action of this complaint. as well as any other violations of Business and 27 Professions Code §17200 - §17208. 28 (b) Violating Health and Safety Code §§ 25503.5 and/or 25505. H--AHOME\EANTOLINUUAN'S.WPD 3.