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I 10. Defendant DOES 1 through 20 are connected and responsible for the acts complained of 2 below. Their real names are unknown at this time, and the People will amend this complaint at a later 3 date when the true identities of DOES 1 through 20 are discovered. 4 FIRST CAUSE OF ACTION 5 VIOLATION OF HEALTH AND SAFETY CODE 6 CHAPTER 6.95 (EMERGENCY BUSINESS RESPONSE PLANS) 7 11. Plaintiff is informed and believes and based upon such information and belief alleges that 8 beginning at an exact date that is unknown to plaintiff, but within one (1) year prior to the filing of this 9 complaint, defendants engaged in acts in violation of Health and Safety Code Chapter 6.95. 10 12. The violations of Health and Safety Code Chapter 6.95 include but are not limited to the 11 following: 12 12a. Violation of Health and Safety Code § 25503.5 by being a business which handles 13 hazardous materials of more than 55 gallons, 500 pounds or 200 cubic feet including but not limited to 14 CARBON DIOXIDE and not having established a business plan for emergency response for 1304 E. 15 HAMMER LANE, SUITE #1, STOCKTON, CALIFORNIA 95210. 16 12b. Violation of Health and Safety Code § 25505 by failing to file an emergency business 17 response plan for 1999 for 1304 E. HAMMER LANE, SUITE#1, STOCKTON,CALIFORNIA 95210, 18 with the San Joaquin County Office of Emergency Services. Further,it is alleged that said violation was 19 knowingly committed after reasonable notice. ' 20 13. It is further alleged that defendants had reasonable notice of the violations contained in 21 paragraphs 12a- 12b above on or about January 1, 1999 and that each day of violation thereafter was 22 a knowing violation as defined in Health and Safety Code § 25514. 23 SECOND CAUSE OF ACTION 24 VIOLATION OF BUSINESS AND PROFESSIONS 25 CODE SECTIONS 17200 - 17208 26 UNLAWFUL AND/OR UNFAIR COMPETITION 27 14. Plaintiff incorporates by reference paragraphs 1 - 20, above. 28 3.