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a <br /> 1 JURISDICTION AND VENUE <br /> 2 3. The defendants transact 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 been <br /> 4 carried out within said San Joaquin County and elsewhere throughout the State of California. The <br /> 5 alleged actions of the defendants and each of them,jointly and separately, as set out below, are in <br /> 6 violation of the law and public policy of the State of California. Unless enjoined and restrained by <br /> 7 an order of this court, the defendants will continue to retain the means to engage in unlawful action <br /> 8 and practices and courses of conduct set out below. <br /> 9 DEFENDANTS <br /> 10 4. Defendant SUPER STOP GAS AND FOOD, a sole proprietorship, a business of <br /> 11 unknown type of organization,is, and at all times relevant herein was, engaged in the business of <br /> 12 GASOLINE STATION AND MINI-MARKET RETAIL SALES, located at 515 W. 11TH STREET, <br /> 13 TRACY, CALIFORNIA. <br /> 14 5. Defendant, RAMESH BIRLA,individually and as sole proprietor of SUPER STOP <br /> 15 GAS AND FOOD, a sole proprietorship, a business of unknown type of organization,is, and at all <br /> 16 times relevant herein was, engaged in the business of GASOLINE STATION AND MINI- <br /> 17 MARKET RETAIL SALES,located at 515 W. 11TH STREET,TRACY,CALIFORNIA. <br /> 18 6. Defendant, RAMESH KUMAR BIRLA JR.,individually and as sole proprietor of <br /> 19 SUPER STOP GAS AND FOOD, a sole proprietorship, a business of unknown type of organization, <br /> 20 is, and at all times relevant herein was, engaged in the business of GASOLINE STATION AND <br /> 21 MINI-MARKET RETAIL SALES, located at 515 W. 11TH STREET,TRACY, CALIFORNIA. <br /> 22 7. Defendant SB GAS &MARKET,a sole proprietorship, a business of unknown type <br /> 23 of organization,is, and at all times relevant herein was,engaged in the business of GASOLINE <br /> 24 STATION AND MINI-MARKET RETAIL SALES, located at 515 W. 11TH STREET,TRACY, <br /> 25 CALIFORNIA. <br /> 26 8. Defendant, SANJAY BIRLA, individually and as sole proprietor of SB GAS & <br /> 27 MARKET, a sole proprietorship, a business of unknown type of organization,is, and at all times <br /> 28 relevant herein was, engaged in the business of GASOLINE STATION AND MINI-MARKET <br /> Complaint for Injunction,Civil Penalties and Other Relief Page 2 <br />