SITE INFORMATION AND CORRESPONDENCE

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' I 1 DEFENDANT 2 3. The defendant'transacts business within the County of San Joaquin and elsewhere 3 throughout the State of California. The alleged violatio as of the law, hereinafter described, have 4 been carried out within said!San Joaquin County. Th alleged actions of the defendant, as set S out below, are in violation of the Iaw and public policy of the State of California. 4 i 6 4. Whenever in ;this complaint reference is made to any act of defendant, such 7 allegation shall be deemed .to mean that defendant and its officers, agents, employees, or 8 representatives, did or authorized acts while actively engaged in the management, direction or a 9 control of the affairs of said defendant, and while acting, within the course and scope of their 10 duties. 11 5. Defendant BC REAL ESTATE INVESTMENTS, INC., a corporation duly 12 organized under the laws of the State of Delaware, is Aow and at all times relevant herein was hl 13 engaged in the business of owning and leasing property orated at 514 W. Kettieman Lane, Lodi, j i� t 14 CA. i 15 FIRST CAUSE OFA TION ?6 VIOLATION OF BUSINESS AND I ROFESSIONS CODE 17 SECTIONS 17200 ET SEQ. (UNI AVVTUL AND/OR 18 UNFAIR COMPETI ION) 19 } 20 6. Paragraphs 1 through 5 above are incorporated herein by reference. Plaintiff is } i 21 informed and believes and biased on such information and belief alleges that beginning at an 22 exact date that is unknown to plaintiff, but within fur (4) years prior to the filing of this a 23 complaint, defendant engaged in acts of unlawful aild/or unfair competition prohibited by 24 California Business and Professions Code § 17200 § 17208 by accidentally damaging a �i 25 groundwater monitoring well,, as described below, wh ch act of accidental damage constitutes it 26 an unlawful and/or unfair business practice: i �i �k