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1 S . Defendant DOES 1 through 10 are connected and <br /> 2 responsible for the acts complained of below. Their real names <br /> 3 are unknown at this time, and the People will amend this <br /> 4 complaint at a later date when the true identities of DOES 1 <br /> 5 through 10 are discovered. <br /> 6 FIRST CAUSE OF ACTION <br /> 7 VIOLATION OF HEALTH AND SAFETY CODE <br /> 8 CHAPTER 6.95 (EMERGENCY BUSINESS RESPONSE PLANS) <br /> 9 <br /> 10 9 . Plaintiff is informed and believes and based upon such <br /> 11 information and belief alleges that beginning at an exact date <br /> 12 that is unknown to plaintiff, but within one (1) year prior to <br /> 13 the filing of this complaint, defendants engaged in acts in <br /> 14 violation of Health and Safety Code Chapter 6. 95. <br /> 15 10. The violations of Health and Safety Code Chapter 6. 95 <br /> 16 include but are not limited to the following: <br /> 17 10a. Violation of Health and Safety Code 5 25503 . 5 by being <br /> 18 a business which handles hazardous materials of more than 55 <br /> 19 gallons, 500 pounds or 200 cubic feet including but not limited <br /> 20 to solvent, oil, diesel, acetylene, oxygen and not having <br /> established a business plan for emergency response for 850 W. <br /> 21 <br /> 22 Milgeo Road, Ripon, California. <br /> 23 lob. violation of Health and Safety Code 5 25505 by failing <br /> 24 to file an emergency business response plan for 1993 for 850 W. <br /> 25 Milgeo Road, Ripon, California, with the San Joaquin County <br /> 26 Office of Emergency Services. Further, it is alleged that said <br /> 27 violation was knowingly committed after reasonable notice. <br /> 28 11. It is further alleged that defendants had reasonable <br /> 3 <br />