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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 />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 California. <br />The alleged actions of the Defendants and each of them, jointly and separately, as set out below, are <br />in violation of the law and public policy of the State of California. Unless enjoined and restrained by <br />an order of this court, the Defendants will continue to retain the means to engage in unlawful action <br />and practices and courses of conduct set out below. <br />DEFENDANTS <br />4. Defendant LADD'S MARINA, a business of unknown type of organization, is, and at all <br />times relevant herein was, engaged in the business of FULL SERVICE BOAT YARD AND <br />MARINA, located at 4911 BUCKLEY COVE WAY, STOCKTON, CALIFORNIA. <br />5. Defendant LADD'S STOCKTON MARINA, a business of unknown type of organization, <br />is, and at all times relevant herein was, engaged in the business of FULL SERVICE BOAT YARD <br />AND MARINA, located at 4911 BUCKLEY COVE WAY, STOCKTON, CALIFORNIA. <br />6. Defendant PATRICIA BONNIFIELD, individually and d.b.a. LADD'S MARINA, is, and <br />at all times relevant herein was, engaged in the business of FULL SERVICE BOAT YARD AND <br />MARINA, located at 4911 BUCKLEY COVE WAY, STOCKTON, CALIFORNIA. <br />7. Defendant PATRICIA BONNIFIELD, individually and d.b.a. LADD'S STOCKTON <br />MARINA, is, and at all times relevant herein was, engaged in the business of FULL SERVICE <br />BOAT YARD AND MARINA, located at 4911 BUCKLEY COVE WAY, STOCKTON, <br />CALIFORNIA. <br />8. Defendant DOES ONE through TWENTY are connected and responsible for the acts <br />complained of below. Their real names are unknown at this time, and the People will amend this <br />Complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br />9. Whenever in this Complaint reference is made to any act of Defendants, such allegation <br />shall be deemed to mean that Defendants and their officers, agents, employees, or representatives, <br />did or authorized acts while actively engaged in the management, direction, or control of the affairs <br />of said Defendants, and while acting within the course and scope of their duties. <br />10. All Defendants at all times acted as agents of one another. With regard to the conduct <br />-2- <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />