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1 8. Defendant JOE DANGTRAN, individually and as an officer of DANGTRAN
<br /> 2 INVESTMENTS, INC., a corporation is, and at all times relevant herein was, engaged in the business
<br /> 3 of GASOLINE STATION, located at 717 W. 8TH STREET, STOCKTON, CALIFORNIA.
<br /> 4 9. Defendant PHUONG-UYEN DANGTRAN, individually and as an officer of
<br /> 5 DANGTRAN INVESTMENTS, INC., a corporation is, and at all times relevant herein was,engaged
<br /> 6 in the business of GASOLINE STATION, located at 717 W. 8TH STREET, STOCKTON,
<br /> 7 CALIFORNIA.
<br /> 8 10. Defendant DANGTRAN INVESTMENTS, INC., a corporation d.b.a. SHELL I-5, a
<br /> 9 business of unknown type of organization, is, and at all times relevant herein was, engaged in the
<br /> 10 business of GASOLINE STATION, located at 717 W. 8TH STREET, STOCKTON, CALIFORNIA.
<br /> 11 11. Defendant JOE DANGTRAN, individually and as an officer of DANGTRAN
<br /> 12 INVESTMENTS, INC., a corporation d.b.a. SHELL I-5 is, and at all times relevant herein was,
<br /> c
<br /> 13 engaged in the business of GASOLINE STATION, located at 717 W. 8TH STREET, STOCKTON,
<br /> 14 CALIFORNIA.
<br /> 15 12. Defendant PHUONG-UYEN DANGTRAN, individually and as an officer of
<br /> 16 DANGTRAN INVESTMENTS, INC., a corporation d.b.a. SHELL I-5 is, and at all times relevant
<br /> 17 herein was, engaged in the business of GASOLINE STATION, located at 717 W. 8TH STREET,
<br /> 18 STOCKTON, CALIFORNIA.
<br /> 19 13. Defendant DOES ONE through FIFTY are connected and responsible for the acts
<br /> 20 complained of below. Their real names are unknown at this time, and the People will amend this
<br /> 21 complaint at a later date when the true identities of DOES ONE through FIFTY are discovered.
<br /> 22 14. Whenever in this Complaint reference is made to any act of Defendants, such allegation
<br /> 23 shall be deemed to mean that Defendants and their officers, agents, employees, or representatives, did
<br /> 24 or authorized acts while actively engaged in the management, direction, or
<br /> 25 control of the affairs of said Defendants, and while acting within the course and scope of their duties.
<br /> 26
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<br /> VERIFIED COMPLAINT
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