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throughout the State of California. The alleged violations of the law, hereinafter described, have <br />been carried out within said San Joaquin County and elsewhere throughout the State of California. <br />The alleged actions of the Defendants and each of them, jointly and separately, as set out below, are <br />in 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 />DEFENDANTS <br />4. Defendant BULK TRANSPORTATION, a California corporation, a business of unknown <br />type of organization, is, and at all times relevant herein was, engaged in the business of <br />TRANSPORTATION OF DRY AND LIQUID COMMODITIES, located at 3032 S. EL DORADO <br />STREET, STOCKTON, CALIFORNIA. <br />5. Defendant DOES ONE through TWENTY is 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 />6. Whenever in this Complaint reference is made to any act of Defendants, such allegation <br />shall be deemed to mean that Defendants and their officers, agents, employees, or representatives, <br />did or authorized acts while actively engaged in the management, direction, or control of the affairs <br />of said Defendants, and while acting within the course and scope of their duties. <br />7. All Defendants at all times acted as agents of one another. With regard to the conduct and <br />omissions alleged in this Complaint, each of the Defendants ratified the actions of the other <br />I Defendants. <br />FIRST CAUSE OF ACTION <br />VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. <br />(HAZARDOUS WASTE CONTROL ACT) <br />8. Plaintiff is informed and believes and based on such information and belief alleges that <br />beginning at an exact date that is unknown to Plaintiff, but within five (5) years prior to the filing of <br />this Complaint (CCP §338.1), Defendants engaged in acts in violation of Health and Safety Code <br />I §25100 et seq., including but not limited to the following: <br />-2- <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />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