Laserfiche WebLink
0 <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 <br />WILLIAM D. SCHMICKER, individually and as a <br />partner of VILLAGE WEST MARINA <br />INVESTORS, a California Limited Partnership; <br />DASCH, Inc., a California corporation; <br />WILLIAM SCHMICKER, individually and as an <br />officer of DASCH, Inc., a California corporation; <br />DWIGHT D. DAVIS, individually and as an officer <br />of DASCH, Inc., a California corporation; <br />and DOES 1 through 50 <br />1. The authority of the District Attorney of San Joaquin County to bring this action is <br />derived from statutory language of the State of California, specifically Health and Safety Code <br />sections 25182, 25189(d), and 25189.1, Health and Safety Code section 25299.02, and Business <br />and Professions Code sections 17204 and 17206. <br />2. THE PEOPLE OF THE STATE OF CALIFORNIA, by and through JAMES P. <br />WILLETT, District Attorney of San Joaquin County, bring this action in the public interest and <br />in the name of THE PEOPLE OF THE STATE OF CALIFORNIA and hereby allege: <br />JURISDICTION AND VENUE <br />3. The Defendants transact business within the County of San Joaquin and elsewhere <br />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 <br />California. The alleged actions of the Defendants and each of them, jointly and separately, as set <br />out below, are in violation of the law and public policy of the State of California. Unless <br />enjoined and restrained by an order of this court, the Defendants will continue to retain the means <br />to engage in unlawful action and practices and courses of conduct set out below. <br />DEFENDANTS <br />4. Defendant VILLAGE WEST YACHT CLUB, a California limited partnership, a <br />11 business of unknown type of organization, is, and at all times relevant herein was, engaged in the <br />business of MARINA AND BOAT STORAGE, located at 6649 EMBARCADERO DRIVE, <br />STOCKTON, CALIFORNIA. <br />5. Defendant ROGER BEEBE, individually and as an officer of VILLAGE WEST <br />11 YACHT CLUB, a California corporation, a business of unknown type of organization, is, and at <br />4 <br />VERIFIED COMPLAINT <br />