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A <br /> DEFENDANT <br /> 2 3. The defendant transacts business within the County of San Joaquin and elsewhere <br /> 3 throughout the State of California. The alleged violations of the law, hereinafter described, have <br /> 4 been carried out within said San Joaquin County. T e alleged actions of the defendant, as set <br /> 5 out below, are in violation of the law and public policy of the State of California. <br /> 6 4. Whenever in this complaint reference is made to any act of defendant, such <br /> 7 allegation shall be deemed to mean that defendant and its officers, agents, employees, or <br /> 8 representatives, did or authorized acts while actively engaged in the management, direction or <br /> 9 control of the affairs of said defendant, and while acting within the course and scope of their <br /> 10 duties. <br /> 11 5. Defendant BC REAL ESTATE INVESTMENTS, INC., a corporation duly <br /> 12 organized under the laws of the State of Delaware, is now and at all times relevant herein was <br /> 13 engaged in the business of owning and leasing property located at 514 W. Kettleman Lane, Lodi, <br /> 14 CA. <br /> 15 FIRST CAUSE OF ACTION <br /> 16 VIOLATION OF BUSINESS ANIE PROFESSIONS CODE <br />_ 17 SECTIONS 17200 ET SEQ. (U LAWFUL AND/OR <br /> 18 UNFAIR COMPETITION) <br /> 19 <br /> 20 6. Paragraphs 1 through 5 above are inc rporated herein by reference. Plaintiff is <br /> 21 informed and believes and based on such informati n and belief alleges that beginning at an <br /> 22 exact date that is unknown to plaintiff, but within four (4) years prior to the filing of this <br /> 23 complaint, defendant engaged in acts of unlawful and/or unfair competition prohibited by <br /> 24 California Business and Professions Code § 1720 - § 17208 by accidentally damaging a <br /> 25 groundwater monitoring well, as described below, which act of accidental damage constitutes <br /> 26 an unlawful and/or unfair business practice: <br />