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1 violation of the law and public policy of the State of California. Unless enjoined and restrained by <br /> 2 an order of this court, the defendants will continue to retain the means to engage in unlawful action <br /> 3 and practices and courses of conduct set out below. <br /> 4 DEFENDANTS <br /> 5 4. Defendant, SIERRA CHEMICAL CO., a Nevada corporation, a business of unknown <br /> 6 type of organization, doing business as NEVADA SIERRA CHEMICAL CO., is, and at all times <br /> 7 relevant herein was, engaged in the business of TOTAL CHEMICAL NEEDS, located at 1010 <br /> 8 INDUSTRIAL DRIVE, STOCKTON, CALIFORNIA. <br /> 9 5. Defendant, STANLEY K. KINDER, individually and as officer of SIERRA <br /> 10 CHEMICAL CO., a Nevada corporation, a business of unknown type of organization, doing <br /> 11 business as NEVADA SIERRA CHEMICAL CO., is, and at all times relevant herein was, engaged <br /> 12 in the business of TOTAL CHEMICAL NEEDS, located at 1010 INDUSTRIAL DRIVE, <br /> 13 STOCKTON, CALIFORNIA. <br /> 14 6. Defendant DOES ONE through TWENTY are connected and responsible for the acts <br /> 15 complained of below. Their real names are unknown at this time, and the People will amend this <br /> 16 complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br /> 17 7. Whenever in this complaint reference is made to any act of defendants, such <br /> 18 allegation shall be deemed to mean that defendants and their officers, agents, employees, or <br /> 19 representatives, did or authorized acts while actively engaged in the management, direction, or <br /> 20 control of the affairs of said defendant, and while acting within the course and scope of their duties. <br /> 21 8. All defendants at all times acted as agents of one another. With regard to the conduct <br /> 22 and omissions alleged in this Complaint, each defendant ratified the actions of the other defendants. <br /> 23 FIRST CAUSE OF ACTION <br /> 24 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. <br /> 25 (HAZARDOUS WASTE CONTROL ACT) <br /> 26 9. Paragraphs 1 through 8, above are incorporated herein by reference. Plaintiff is <br /> 27 informed and believes and based upon such information and belief alleges that beginning at an exact <br /> 28 date that is unknown to plaintiff, but within five (5) years prior to the filing of this complaint(CCP <br /> Complaint for Injunction,Civil Penalties and Other Relief Page 2 <br />