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• <br /> 1 enjoined and restrained by an order of this court, the defendants will continue to retain the means <br /> 2 to engage in unlawful action and practices and courses of conduct set out below. <br /> 3 DEFENDANTS <br /> 4 4. Defendants ARTHUR KATZAKIAN and JERRY KATZAKIAN, are, and at all times <br /> 5 relevant herein were, engaged in the business of PROPERTY MANAGEMENT, located at <br /> 6 15431 LOWER SACRAMENTO ROAD, LODI, CALIFORNIA. <br /> 7 5 Whenever in this complaint reference is made to any act of defendants, such allegation <br /> 8 shall be deemed to mean that defendants and its officers, agents, employees, or representatives, <br /> 9 did or authorized acts while actively engaged in the management, direction, or control of the <br /> 10 affairs of said defendant, and while acting within the course and scope of their duties. <br /> 11 6. All defendants at all times acted as agents for one another. With regard to the conduct <br /> 12 and omissions alleged in the Complaint, each of the defendants ratified the actions of the other <br /> 13 defendants. <br /> 14 <br /> 15 <br /> 16 FIRST CAUSE OF ACTION <br /> 17 VIOLATION OF HEALTH AND SAFETY CODE <br /> 18 SECTIONS 25280 ET.SEQ. (UNDERGROUND STORAGE OF <br /> 19 HAZARDOUS MATERIALS) <br /> 20 7. Plaintiff is informed and believes and based upon such information and belief alleges <br /> 21 that beginning at an exact date that is unknown to plaintiff,but within five (5) years prior to the <br /> 22 filing of this complaint, defendants have violated Health and Safety Code Chapter 6.7 by failing <br /> 23 to obtain a timely permit to remove and close an underground storage tank (UST). <br /> 24 <br /> 25 PRAYER <br /> 26 WHEREFORE,Plaintiff prays that: <br /> 27 1. Defendants be permanently restrained and enjoined from engaging in or performing, <br /> 28 directly or indirectly, any and all of the following acts: <br />