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0 <br /> 1 JURISDICTION AND VENUE <br /> 2 3. The Defendants transact business within the County of San Joaquin. The alleged <br /> 3 violations of the law,hereinafter described,have been carried out within said San Joaquin County. <br /> 4 The alleged actions of the Defendants and each of them,jointly and separately, as set out below,are <br /> 5 in violation of the law and public policy of the State of California. Unless enjoined and restrained by <br /> 6 an order of this court,the Defendants will continue to retain the means to engage in unlawful action <br /> 7 and practices and courses of conduct set out below. <br /> 8 DEFENDANTS <br /> 9 4. Defendant CONVENIENCE RETAILERS, LLC,a Delaware limited liability company, a <br /> 10 business of unknown type of organization,is,and at all times relevant herein was,engaged in the <br /> 11 business of GASOLINE STATION,located at 1469 E.HAMMER LANE, STOCKTON, <br /> 12 CALIFORNIA. <br /> 13 5. Defendants DOES ONE through TWENTY are connected and responsible for the acts <br /> 14 complained of below. Their real names are unknown at this time,and the People will amend this <br /> 15 Complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br /> 16 6. Whenever in this Complaint reference is made to any act of Defendants,such allegation <br /> 17 shall be deemed to mean that Defendants and their officers, agents,employees,or representatives, <br /> 18 did or authorized acts while actively engaged in the management,direction, or control of the affairs <br /> 19 of said Defendants, and while acting within the course and scope of their duties. <br /> 20 <br /> FIRST CAUSE OF ACTION <br /> 21 <br /> VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br /> 22 (UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br /> 23 7. Plaintiff is informed and believes and based on such information and belief alleges that <br /> 24 beginning at an exact date that is unknown to Plaintiff,but within five(5)years prior to the filing of <br /> 25 this Complaint(CCP §338.1),Defendants engaged in acts in violation of Health and Safety Code <br /> 26 §25280 et seq.,including by not limited to the following: <br /> 27 a. Tampered with or otherwise disabled automatic leak detection devices or alarms, in <br /> 28 violation of Health and Safety Code section 25299(a)(9). <br /> -2- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />