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I alleged violations of the law hereinafter described, have been <br /> 2 carried out within said San Joaquin County and elsewhere throughout <br /> 3 the State of California . The alleged actions of the defendants and <br /> 4 each of them, jointly and separately, as set out below, are in <br /> 5 violation of the law and public policy of the State of California. <br /> 6 Unless enjoined and restrained by an order of this court, the <br /> 7 defendants will continue to retain the means to engage in unlawful <br /> 8 action and practices and courses of conduct set out below. <br /> 9 DEFENDANTS <br /> 10 4 . Whenever in this complaint reference is made to any act of <br /> 11 defendants, such allegation shall be deemed to mean that defendants <br /> 12 and its officers, agents, employees, or representatives, did or <br /> 13 authorized acts while actively engaged in the management, <br /> 14 direction, or control of the affairs of said defendant, and while <br /> 15 acting within the course and scope of their duties . <br /> 16 S . Defendant EUROCORP AVIATION, a business of unknown type of <br /> 17 organization, is, and at all times relevant herein was, engaged in <br /> 18 the business of FLIGHT SCHOOL, located at 12145 DEVIRES RD. , LODI, <br /> 19 CALIFORNIA. <br /> 20 6 . Defendant EUROCORP FINANCIAL, a business of unknown type <br /> 21 of organization, is, and at all times relevant herein was, engaged <br /> 22 in the business of FLIGHT SCHOOL, located at 12145 DEVIRES RD. , <br /> 23 LODI, CALIFORNIA. <br /> 24 7 . Defendant PERRY KOTSOGLOU is, and at all times relevant <br /> 25 herein was, engaged in the business of FLIGHT SCHOOL, located at <br /> 26 12145 N. DEVRIES RD. , LOCI, CALIFORN=A. <br /> 27 8 . Defendant DOES 1 through 10 are connected and responsible I <br /> 28 2 <br /> i <br /> i <br />