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I JOHN D. PHILLIPS <br /> District Attorney <br /> 2 State Bar Membership No. 48474 <br /> San Joaquin County <br /> 3 By: DAVID J. IREY - #142864 <br /> Deputy District Attorney <br /> 4 Environmental Prosecutions Unit <br /> Stockton, CA 95202 <br /> 5 D:EPU:JUAN'Sl <br /> 6 Phone: (209) 468-2400 <br /> 7 Attorneys for Plaintiff <br /> 8 <br /> 9 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN <br /> 10 <br /> 11 The People of the State of California, ) No. OQy,,,099 <br /> 12 Plaintiff, ) COMPLAINT FOR <br /> INJUNCTION, CIVIL <br /> 13 V. ) PENALTIES AND OTHER <br /> RELIEF (Bus. & Prof. <br /> 14 ) Code § 17200 et seq.) y <br /> JUAN'S AUTO REPAIR, ) <br /> 15 JUAN O. MORGA, ) <br /> AND DOES I THROUGH 10 ) <br /> 16 <br /> Defendant(s). <br /> 17 <br /> 18 1. The authority of the District Attorney of San Joaquin County to bring this action is <br /> 19 derived from statutory language of the State of California, specifically Business and Professions <br /> 20 Code §17204 and §17206, Health and Safety Code §§ 25503.5 and 25505. <br /> 21 2. THE PEOPLE OF THE STATE OF CALIFORNIA, by and through JOHN D. PHILLIPS, <br /> 22 District Attorney of San Joaquin County, bring this action in the public interest in the name of THE <br /> 23 PEOPLE OF THE STATE OF CALIFORNIA and hereby allege: <br /> 24 JURISDICTION AND VENUE <br /> 25 3. The defendants transact business within the County of San Joaquin and elsewhere <br /> 26 throughout the State of California. The alleged violations of the law hereinafter described, have been <br /> 27 carried out within said San Joaquin County and elsewhere throughout the State of California. The <br /> 28 alleged actions of the defendants and each of them,jointly and separately, as set out below, are in <br /> H:kH0ME\EANT0LINUUAN'S.WPD �. <br />