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1 of San Joaquin, is authorized, pursuant to Section 25182 of the <br /> 2 Health and Safety Code, to commence a civil action under Chapter <br /> 3 6. 5 of Division 20 of the Health and Safety Code. <br /> 3 . Venue of this action in this County is mandated by <br /> 4 <br /> 5 Health and Safety Code SS 25183 and 25299 . 03 <br /> THE PEOPLE OF THE STATE OF CALIFORNIA, by and through JOHN <br /> 6 <br /> 7 D. PHILLIPS, District Attorney of the County of San Joaquin, <br /> 8 hereby allege that: <br /> 9 DEFENDANTS <br /> 10 4 . Defendants, transact business within the County of San <br /> 11 Joaquin. The violations hereinafter described have been carried <br /> 12 out within San Joaquin County. <br /> 13 5. Defendant BRADLEY K. FRAHM, is now, and at all times <br /> 14 mentioned herein, was engaged in the business of contractor <br /> 15 services and underground storage tank removal located at 820 <br /> 16 South American Street, Stockton, within San Joaquin County. <br /> 17 FRAHM is the Chief Executive Officer of defendant SIEBOLD <br /> 18 CORPORATION. <br /> 19 5a. Defendant SIEBOLD CORPORATION, is now, and at all times <br /> 20 mentioned herein, a California . Corporation was engaged in the <br /> 21 business of contractor services and underground storage tank <br /> 22 -removal with its principal place of business located at 820 <br /> 23 South American Street, Stockton, California, a location within <br /> 24 San Joaquin County. <br /> 25 6. The true names or capabilities, whether individual, <br /> 26 corporate, associate, or otherwise, of defendants DOES ONE <br /> 27 through ONE HUNDRED are unknown to plaintiff who therefore sues <br /> 28 <br /> 2 <br />