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i <br /> 1 II <br /> 2 JURISDICTION AND VENUE <br /> 3 15, THE PEOPLE OF THE STATE OF CALIFORNIA, by and through JOHN D. PHILLIPS, <br /> 4 District Attorney of San Joaquin County,acting to protect the public from health and safety hazards, <br /> 5 and from unfair, unlawful or fraudulent business practices, and to protect the environment of the <br /> 6 County of San Joaquin, brings this action in the public interest in the name of the PEOPLE OF THE <br /> 7 STATE OF CALIFORNIA. <br /> 8 16. Plaintiff, by this action and pursuant to Health and Safety Code sections 25299, 25299.01, <br /> 9 25299.37, 25299.76, 42400, Business and Professions Code sections 17200, 17203, 17204, and <br /> 10 17206, and California Code of Regulations, Title 23, Division 3, Chapter 16, Article 11 sections <br /> 11 2721-2728, inclusive, seeks to enjoin Defendants from engaging in further violations of the laws and <br /> 12 regulations alleged herein and seeks to obtain civil penalties for the Defendants' violations of the <br /> 13 above-mentioned laws and regulations. <br /> 14 17. San Joaquin County Public Health Services Environmental Health Division ("PHS-EHD") <br /> 15 is the agency whose responsibilities include implementation of Chapter 6.7 of the California Health <br /> 16 and Safety Code (Underground Storage of Hazardous Substances) and implementation of Chapter <br /> 17 6.75 of the California Health and Safety Code (Petroleum Underground Storage Tank Cleanup) <br /> 18 within San Joaquin County. This includes inspections of Underground Storage Tanks("USTs")and <br /> 19 issuing permits and performing inspections for installations, removals, upgrades, and repairs. <br /> 20 Additionally, this includes San Joaquin County oversight of the corrective action mandated to taken <br /> 21 by the owner and/or operator of a tank whenever an unauthorized release threatens human health <br /> 22 safety, or the environment. <br /> 23 18. Defendant transacts business within the County of San Joaquin and elsewhere within the <br /> 24 State of California. The violations of law hereinafter described have been carried out wholly or in <br /> 25 part within the County of San Joaquin. <br /> 26 111 <br /> 27 111 <br /> 28 111 <br /> H:SHOW MYOUNG5CASESIUNOCAL\COMPLAIN.WPD 3 <br />