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