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I JAMES P. WILLETT, District Attorney of the County of San Joaquin 2 DAVID J. IREY, SBN 142864 Supervising Deputy District Attorney 3 CELESTE KAISCH, SBN 234174 Deputy District Attorney 4 Environmental Prosecutions Unit 222 E. Weber Ave, Room 202 5 Stockton, CA 95202 6 Phone: (209)468-2400 7 Attorneys for Plaintiff 8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN 9 10 The People Of The State Of California, ) Case No. ) Plaintiff, ) 11 ) VERIFIED COMPLAINT FOR V. ) INJUNCTION, CIVIL PENALTIES 12 ) AND OTHER RELIEF SIERRA CHEMICAL CO., a Nevada Corporation ) 13 d.b.a. NEVADA SIERRA CHEMICAL CO.; ) (Health& Safety Code §25100 et seq., STANLEY K. KINDER, individually and as officer of Health & Safety Code §25500 et seq., 14 SIERRA CHEMICAL CO., a Nevada Corporation; ) and Business & Professions Code 15 DOES 1 THROUGH 20, inclusive, ) §17200 et seq.) ) 16 Defendant(s), ) 17 1. The authority of the District Attorney of San Joaquin County to bring this action is 18 derived from statutory language of the State of California, specifically Health and Safety Code 19 sections 25182, 25189(d) and 25189.1, Health and Safety Code sections 25514, 25516, 25516.1, 20 25516.2 and Business and Professions Code sections 17204 and 17206. 21 2. THE PEOPLE OF THE STATE OF CALIFORNIA, by and through JAMES P. 22 WILLETT, District Attorney of San Joaquin County,bring this action in the public interest in the 23 name of THE PEOPLE OF THE STATE OF CALIFORNIA and hereby allege: 24 JURISDICTION AND VENUE 25 3. The defendants transact business within the County of San Joaquin and elsewhere 26 throughout the State of California. The alleged violations of the law hereinafter described, have been 27 carried out within said San Joaquin County and elsewhere throughout the State of California. The 28 alleged actions of the defendants and each of them,jointly and separately, as set out below, are in Complaint for Injunction,Civil Penalties and Other Relief Page I