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I FIRST CAUSE OF ACTION 2 VIOLATION OF HEALTH AND SAFETY CODE 3 CHAPTER 6.95 (EMERGENCY BUSINESS RESPONSE PLANS) 4 11. Plaintiff is informed and believes and based upon such information and belief alleges that 5 beginning at an exact date that is unknown to plaintiff, but within one (1) year prior to the filing of this 6 complaint, defendants engaged in acts in violation of Health and Safety Code Chapter 6.95. 7 12. The violations of Health and Safety Code Chapter 6.95 include but are not limited to the 8 following: 9 12a. Violation of Health and Safety Code § 25503.5 by being a business which handles 10 hazardous materials of more than 55 gallons, 500 pounds or 200 cubic feet including but not limited to 11 CARBON DIOXIDE and not having established a business plan for emergency response for 1419 S. 12 EL DORADO, STOCKTON, CALIFORNIA 95206. 13 12b. Violation of Health and Safety Code § 25505 by failing to file an emergency business 14 response plan for 1999 for 1419 S. EL DORADO, STOCKTON, CALIFORNIA 95206, with the San 15 Joaquin County Office of Emergency Services. Further, it is alleged that said violation was knowingly 16 committed after reasonable notice. 17 13. It is further alleged that defendants had reasonable notice of the violations contained in I 18 paragraphs 12a- 12b above on or about January 1, 1999 and that each day of violation thereafter was 19 a knowing violation as defined in Health and Safety Code § 25514. 20 SECOND CAUSE OF ACTION 21 VIOLATION OF BUSINESS AND PROFESSIONS 22 CODE SECTIONS 17200 - 17208 23 UNLAWFUL AND/OR UNFAIR COMPETITION 24 14. Plaintiff incorporates by reference paragraphs 1 - 20, above. 25 15. Plaintiff is informed and believes and based on such information and belief alleges that 26 beginning at an exact date that is unknown to plaintiff, but within four(4)years prior to the filing of this 27 complaint, defendants have engaged in acts of unlawful and/or unfair competition prohibited by 28 3.