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 />
|