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I JURISDICTION AND VENUE <br /> 2 3. The Defendants transact business within the County of San Joaquin. The alleged <br /> 3 violations of the law, hereinafter described,have been carried out within said San Joaquin County. <br /> 4 The alleged actions of the Defendants and each of them,jointly and separately,as set out below,are <br /> 5 in violation of the law and public policy of the State of California. Unless enjoined and restrained by <br /> 6 an order of this court,the Defendants will continue to retain the means to engage in unlawful action <br /> 7 and practices and courses of conduct set out below. <br /> 8 DEFENDANTS <br /> 9 4. Defendant LATHROP GAS AND FOOD, a business of unknown type of organization,is, <br /> 10 and at all times relevant herein was,engaged in the business of GAS STATION, located at 14800 S. <br /> 11 HWY 99, MANTECA, CALIFORNIA. <br /> 12 5. Defendant JARNAIL S. KAMBOJ, individually and dba LATHROP GAS AND FOOD is, <br /> 13 and at all times relevant herein was, engaged in the business of GAS STATION, located at 14800 S. <br /> 14 HWY 99, MANTECA,CALIFORNIA. <br /> 15 6. Defendant DOES ONE through TWENTY are connected and responsible for the acts <br /> 16 complained of below. Their real names are unknown at this time, and the People will amend this <br /> 17 Complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br /> 18 7. Whenever in this Complaint reference is made to any act of Defendants, such allegation <br /> 19 shall be deemed to mean that Defendants and their officers, agents,employees, or representatives, <br /> 20 did or authorized acts while actively engaged in the management, direction, or control of the affairs <br /> 21 of said Defendants,and while acting within the course and scope of their duties. <br /> 22 <br /> FIRST CAUSE OF ACTION <br /> 23 <br /> VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br /> 24 (UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br /> 25 8. Plaintiff is informed and believes and based on such information and belief alleges that <br /> 26 beginning at an exact date that is unknown to Plaintiff,but within five(5)years prior to the filing of <br /> 27 this Complaint(CCP §338.1),Defendants engaged in acts in violation of Health and Safety Code <br /> 28 §22580 et seq., including by not limited to the following: <br /> -2- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />