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I 10. Defendant DOES 1 through 20 are connected and responsible for the acts complained of <br /> 2 below. Their real names are unknown at this time, and the People will amend this complaint at a later <br /> 3 date when the true identities of DOES 1 through 20 are discovered. <br /> 4 FIRST CAUSE OF ACTION <br /> 5 VIOLATION OF HEALTH AND SAFETY CODE <br /> 6 CHAPTER 6.95 (EMERGENCY BUSINESS RESPONSE PLANS) <br /> 7 11. Plaintiff is informed and believes and based upon such information and belief alleges that <br /> 8 beginning at an exact date that is unknown to plaintiff,but within one (1) year prior to the filing of this <br /> 9 complaint, defendants engaged in acts in violation of Health and Safety Code Chapter 6.95. <br /> 10 12. The violations of Health and Safety Code Chapter 6.95 include but are not limited to the <br /> 11 following: <br /> 12 12a. Violation of Health and Safety Code § 25503.5 by being a business which handles <br /> 13 hazardous materials of more than 55 gallons, 500 pounds or 200 cubic feet including but not limited to <br /> 14 CARBON DIOXIDE and not having established a business plan for emergency response for 1048 E. <br /> 15 WATERLOO ROAD, STOCKTON, CALIFORNIA 95205. <br /> 16 12b. Violation of Health and Safety Code § 25505 by failing to file an emergency business <br /> 17 response plan for 1999 for 1048 E. WATERLOO ROAD, STOCKTON, CALIFORNIA 95205, with l <br /> 18 the San Joaquin County Office of Emergency Services. Further, it is alleged that said violation was <br /> 19 knowingly committed after reasonable notice. <br /> 20 13. It is further alleged that defendants had reasonable notice of the violations contained in <br /> 21 paragraphs 12a- 12b above on or about January 1, 1999 and that each day of violation thereafter was <br /> 22 a knowing violation as defined in Health and Safety Code § 25514. <br /> 23 <br /> 24 <br /> 25 HI <br /> 26 <br /> 27 <br /> 28 3. <br />