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t <br /> 1 1. The authority of the District Attorney of San Joaquin County to bring this action is derived <br /> 2 from statutory language of the State of California, specifically Health and Safety Code sections <br /> 3 25182, 25189(d), and 25189.1, Health and Safety Code section 25299.02, and Business and <br /> 4 Professions Code sections 17204 and 17206. <br /> 5 2. THE PEOPLE OF THE STATE OF CALIFORNIA, by and through JAMES P. WILLETT, <br /> 6 District Attorney of San Joaquin County, bring this action in the public interest and in the name of <br /> 7 THE PEOPLE OF THE STATE OF CALIFORNIA and hereby allege: <br /> 8 JURISDICTION AND VENUE <br /> 9 3. The Defendants transact business within the County of San Joaquin and elsewhere <br /> 10 throughout the State of California. The alleged violations of the law, hereinafter described, have been <br /> 11 carried out within said San Joaquin County and elsewhere throughout the State of California. The <br /> 12 alleged actions of the Defendants and each of them,jointly and separately, as set out below, are in <br /> 13 violation of the law and public policy of the State of California. Unless enjoined and restrained by an <br /> 14 order of this court, the Defendants will continue to retain the means to engage in unlawful action and <br /> 15 practices and courses of conduct set out below. <br /> 16 DEFENDANTS <br /> 17 4. Defendant SHELL I-5, a business of unknown type of organization, is, and at all times <br /> 18 relevant herein was, engaged in the business of GASOLINE STATION, located at 717 W. 8' <br /> 19 STREET, STOCKTON, CALIFORNIA. <br /> 20 5. Defendant JOE DANGTRAN, individually and d.b.a. SHELL I-5 is,and at all times <br /> 21 relevant herein was,engaged in the business of GASOLINE STATION, located at 717 W. 8' <br /> 22 STREET, STOCKTON, CALIFORNIA. <br /> 23 6. Defendant PHUONG-UYEN DANGTRAN,individually and d.b.a. SHELL I-5 is, and at <br /> 24 all times relevant herein was, engaged in the business of GASOLINE STATION, located at 717 W. <br /> 25 8'' STREET, STOCKTON, CALIFORNIA. <br /> 26 7. Defendant DANGTRAN INVESTMENTS, INC., a corporation, a business of unknown <br /> 27 type of organization, is, and at all times relevant herein was, engaged in the business of GASOLINE <br /> 28 STATION, located at 717 W. 8'" STREET, STOCKTON, CALIFORNIA. <br /> 2 <br /> VERIFIED COMPLAINT <br />