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1 2. Pursuant to California Health and Safety Code sections 25514, 25515.2, and 25516.1, <br /> 2 the Attorney General, or the District Attorney may bring a civil action for civil penalties for <br /> 3 violations of California Health and Safety Code sections 25503.5 to 25505, inclusive, or <br /> 4 sections 25508 to 25510, inclusive. Pursuant to California Health and Safety Code section <br /> 5 25516, the District Attorney also may bring an action to enjoin a violation of Chapter 6.95 of <br /> 6 Division 20 of the California Health and Safety Code(hereinafter"Chapter 6.95"). <br /> 7 3. Pursuant to California Business and Professions Code section 17203, 17204, and <br /> 8 17206, the Attorney General and the District Attorney may bring actions in the name of the <br /> 9 People of the State of California in a superior court for an injunction against any person who <br /> 10 engages,had engaged, or proposes to engage in unfair competition and for civil penalties for <br /> 11 each act of unfair competition. <br /> 12 4. Plaintiff brings this action without any prejudice to any other action or claims which <br /> 13 it may have based on separate, independent and unrelated violations of Chapter 6.95 of Division <br /> 14 20 of the California Health and Safety Code by GMRI, Inc., a Florida Corporation and/or on <br /> 15 facts which are not alleged in this complaint. <br /> 16 DEFENDANTS <br /> 17 5. Defendant GMRI, INC., (flea GMRI or"Defendant') is a Florida Corporation which <br /> 18 does business in San Joaquin County, and elsewhere in the State of California, under the names, <br /> 19 Red Lobster or Olive Garden, at the facilities identified in Exhibit"A"which is incorporated <br /> 20 herein by reference (hereinafter collectively referred to as"Covered Facilities"). <br /> 21 6. GMRI is, or at all times relevant to the claims in this complaint was, legally <br /> 22 responsible for compliance with the provisions of Chapters 6.95 of Division 20 of the California <br /> 23 Health and Safety Code at its Covered Facilities. <br /> 24 VENUE <br /> 25 7. Venue is proper in this county in that the Defendant transacts business within the <br /> 26 County of San Joaquin and elsewhere throughout the State of California. The alleged violations <br /> 27 of the law alleged in the Complaint, have been carried out within said San Joaquin County and <br /> 28 elsewhere throughout the State of California. The alleged actions of the Defendant, as set out <br /> z <br /> nn�.TnT ATN Wnn nWTT nFNAT TTFC ANT TN RMl RFT.WF <br />