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I for the acts complained of below. Their real names are unknown at <br /> 2 this time, and the People will amend this complaint at a later date <br /> 3 when the true identities of DOES 1 through 10 are discovered. <br /> 4 QRST CAUSE OF ACTION <br /> 5 VIOLATION OF HEALTH AND SAFETY CODE <br /> 6 CHAPTER 6. 95 (EMERGENCY BUSINESS RESPONSE PLANS) <br /> 7 9. Plaintiff is informed and believes and based upon such <br /> 8 information and belief alleges that beginning at an exact date that <br /> 9 is unknown to plaintiff, but within one (1) year prior to the I <br /> 10 filing of this complaint, defendants engaged in acts in violation <br /> 11 of Health and Safety Code Chapter 6. 95 . I <br /> 12 10 . The violations of Health and Safety Code Chapter 6. 95 <br /> 13 include but are not limited to the following: <br /> 14 10a. Violation of Health and Safety Code§ 25503 . 5 by being a <br /> 15 business which handles hazardous materials of more than 55 gallons, <br /> 16 500 pounds or 200 cubic feet including but not limited to AVIATION <br /> 17 FUEL and not having established a business plan for emergency <br /> 18 response for 12145 N. DEVIRES RD. , LODI, California. <br /> 19 10b. Violation of Health and Safety Code § 25505 by failing <br /> 20 to file an emergency business response plan for 1996 for 12145 N. <br /> 21 DEVRIES RD. , LODI, CALIFORNIA, with the San Joaquin County Office <br /> 22 of Emergency Services. Further, it is alleged that said violation <br /> 23 was knowingly committed after reasonable notice. <br /> 24 11 . It is further alleged that defendants had reasonable <br /> 7'_5 notice of the violations contained in paragraphs 10a - 10b above on <br /> 26 or about January 1, 1998 and that each day of violation thereafter <br /> 27 was a knowing violation as defined in Health and Safety Code § <br /> 28 <br /> 3. <br />