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I California. California Code of Civil Procedure §392(1). <br /> 2 PARTIES <br /> 3 2. Plaintiff DELTA FUNDING is a limited partnership organized and <br /> 4 existing under the laws of the State of California. The limited partnership consists of Leonette <br /> 5 Belling, Al Gomez, and Sunil Yaday. DELTA FUNDING has filed the statement and <br /> 6 published the notice required by California Business & Professions Code §17918. DELTA <br /> FUNDING's principal place of business is 149 West Yokuts Avenue, Stockton California <br /> 7 95207. At all times relevant hereto, DELTA FUNDING was doing business in San Joaquin <br /> 8 County, California. <br /> 9 3. DELTA FUNDING is informed and believes and on that basis alleges <br /> 10 that Defendant SJPHS-EHD is, and at all times relevant hereto, was a political subdivision of <br /> 11 the State of California and a public agency of San Joaquin County. At all times relevant <br /> 12 hereto, SJPHS-EHD was acting as a local enforcement agency under California Public <br /> 13 Resources Code §§45000,45005 and 45011. <br /> 14 4. Defendants DOES 1 through 50, inclusive, are sued herein under <br /> 15 fictitious names pursuant to California Code of Civil Procedure §474. Plaintiff is ignorant of <br /> the true names or capacities of the defendants sued herein under the fictitious names DOES 1 <br /> 16 <br /> through 50 inclusive. When their true names and capacities are ascertained, Plaintiff will seek <br /> 17 <br /> leave of the court to amend this complaint by inserting their true names and capacities herein. <br /> 18 Plaintiff is informed and believes and on that basis alleges that each of the fictitiously named <br /> 19 defendants is responsible in some manner for Plaintiff's damages. <br /> 20 GENERAL ALLEGATIONS <br /> 21 5. DELTA FUNDING is informed and believes and on that basis alleges <br /> 22 that prior to 1988, the Lynch Property was part of what was known as the Snyder Dump, <br /> F <br /> 23 which was later subdivided into two parcels, one of which became the Lynch Property. <br /> 24 DELTA FUNDING is 'also informed and believes and on that basis alleges that in or about <br /> 25 <br /> 1989, SJPHS-EHD authorities took enforcement action against the owner of the Lynch <br /> 26 <br /> Property, Leonard Lynch, and removed solid waste that had been disposed of at the Lynch <br /> 27 <br /> Property. DELTA FUNDING is further informed and believes that SJPHS-EHD failed to <br /> 28 <br /> 2 <br /> COMPLAINT FOR DECLARATORY RELIEF AND DAMAGES <br />