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I been carried out within said San Joaquin County and elsewhere throughout the State of California. <br /> 2 The alleged actions of the Defendants and each of them,jointly and separately, as set out below, are <br /> 3 in violation of the law and public policy of the State of California. Unless enjoined and restrained by <br /> 4 an order of this court,the Defendants will continue to retain the means to engage in unlawful action <br /> 5 and practices and courses of conduct set out below. <br /> 6 DEFENDANTS <br /> 7 4. Defendant UNIFIRST CORPORATION, a Massachusetts Corporation doing business in <br /> 8 California, a business of unknown type of organization, is, and at all times relevant herein was, <br /> 9 engaged in the business of INDUSTRIAL LAUNDRY, located at 819 NORTH HUNTER STREET, <br /> 10 STOCKTON, CALIFORNIA. <br /> 11 5. Defendant DOES ONE through TWENTY are connected and responsible for the acts <br /> 12 complained of below. Their real names are unknown at this time, and the People will amend this <br /> 13 complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br /> 14 6. Whenever in this Complaint reference is made to any act of Defendants, such allegation <br /> 15 shall be deemed to mean that Defendants and their officers, agents, employees, or representatives, <br /> 16 did or authorized acts while actively engaged in the management, direction, or control of the affairs <br /> 17 of said Defendants, and while acting within the course and scope of their duties. <br /> 18 7. All Defendants at all times acted as agents of one another. With regard to the conduct and <br /> 19 omissions alleged in this Complaint, each of the Defendants ratified the actions of the other <br /> 20 Defendants. <br /> 21 FIRST CAUSE OF ACTION <br /> 22 VIOLATION OF HEALTH AND SAFETY CODE SECTIONS 25500 ET SEQ. <br /> 23 (HAZARDOUS MATERIALS RELEASE RESPONSE PLANS AND INVENTORY) <br /> 24 8. Plaintiff is informed and believes and based upon such information and belief alleges that <br /> 25 beginning at an exact date that is unknown to Plaintiff, but within five(5)years prior to the filing of <br /> 26 this Complaint, Defendant engaged in acts in violation of Health and Safety Code sections 25500 et <br /> 27 seq., including but not limited to the following: <br /> 28 a. Failed to provide training for all new employees and annual training, including <br /> -2- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />