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1 JURISDICTION AND VENUE 2 3. The defendants transact business within the County of San Joaquin and elsewhere 3 throughout the State of California. The alleged violations of the law, hereinafter described, have 4 been carried out within said San Joaquin County and elsewhere throughout the State of 5 California. The alleged actions of the defendants and each of them,jointly and separately, as set 6 out below, are in violation of the law and public policy of the State of California. Unless 7 enjoined and restrained by an order of this court, the defendants will continue to retain the means 8 to engage in unlawful action and practices and courses of conduct set out below. 9 10 DEFENDANTS 11 4. Defendant QUICKI-KLEEN CAR WASH a business of unknown type of 12 organization, is, and at all times relevant herein was, engaged in the business of GASOLINE 13 SALES/MINI-MART/CAR WASH, located at 707 E. YOSEMITE AVE., MANTECA, 14 CALIFORNIA. 15 5. Defendant MARY LOU PONTES is, and at all times relevant herein was, 16 engaged in the business of GASOLINE SALES/MINI-MART/CAR WASH, located at 707 E. 17 YOSEMITE AVE., MANTECA, CALIFORNIA. 18 6. Defendants DOES 1 through 20 are connected and responsible for the acts 19 complained of below. Their real names are unknown at this time, and the People will amend this 20 complaint at a later date when the true identities of DOES 1 through 20 are discovered. 21 7. Whenever in this complaint reference is made to any act of defendants, such 22 allegation shall be deemed to mean that defendants and their officers, agents, employees, or 23 representatives, did or authorized acts while actively engaged in the management, direction, or 24 control of the affairs of said defendants, and while acting within the course and scope of their 25 duties. 26 27 28 H:UiOMET-ANTOL W W STQU[CKBCL.WPD 2