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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 <br /> 4 been carried out within said San Joaquin County and elsewhere throughout the State of California. <br /> 5 The alleged actions of the Defendants and each of them,jointly and separately,as set out below,are <br /> 6 in 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 COUNTRY MART DIESEL& GAS, a business of unknown type of <br /> 11 organization, is,and at all times relevant herein was,engaged in the business of GASOLINE <br /> 12 SALES/MINI-MART, located at 34243 S. CHRISMAN RD.,TRACY,CALIFORNIA. <br /> 13 5. Defendant TARANJIT SANDHU,individually dba COUNTRY MART DIESEL&GAS, <br /> 14 is and at all times relevant herein was,engaged in the business of GASOLINE SALES/MINI- <br /> 15 MART, located at 34243 S. CHRISMAN RD.,TRACY, CALIFORNIA. <br /> 16 6. Defendant BODH KUNWAR, individually dba COUNTRY MART DIESEL& GAS,is <br /> 17 and at all times relevant herein was,engaged in the business of GASOLINE SALES/M1NI-MART, <br /> 18 located at 34243 S. CHRISMAN RD., TRACY,CALIFORNIA. <br /> 19 7. Defendant SINGH PUSHPINDER, individually, is and at all times relevant herein was, <br /> 20 engaged in the business of OWNER OF UNDERGROUND STORAGE TANK SYSTEM AND <br /> 21 PROPERTY,located at 34243 S. CHRISMAN RD.,TRACY, CALIFORNIA. <br /> 22 8. Defendant DOES ONE through FIFTY are connected and responsible for the acts <br /> 23 complained of below. Their real names are unknown at this time,and the People will amend this <br /> 24 complaint at a later date when the true identities of DOES ONE through FIFTY are discovered. <br /> 25 9. Whenever in this Complaint reference is made to any act of Defendants,such allegation <br /> 26 shall be deemed to mean that Defendants and their officers, agents, employees,or representatives, <br /> 27 did or authorized acts while actively engaged in the management,direction,or control of the affairs <br /> 28 2 <br /> VERIFIED COMPLAINT <br />