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I from statutory language of the State of California, specifically Health and Safety Code sections <br /> 2 25182,25189(d), and 25189.1, Health and Safety Code sections 25515, 25515.6, 25515.7, and <br /> 3 25515.8, Fish and Game Code sections 5650 and 5650.1, and Business and Professions Code <br /> 4 sections 17204 and 17206. <br /> 5 2. THE PEOPLE OF THE STATE OF CALIFORNIA,by and through TORI VERBER <br /> 6 SALAZAR, District Attorney of San Joaquin County,bring this action in the public interest and in <br /> 7 the name of THE PEOPLE OF THE STATE OF CALIFORNIA and hereby allege: <br /> 8 JURISDICTION AND VENUE <br /> 9 3. The Defendant transacts 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 <br /> 11 been carried out within said San Joaquin County and elsewhere throughout the State of California. <br /> 12 The alleged actions of the Defendant 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 <br /> 14 an order of this court,the Defendant will continue to retain the means to engage in unlawful action <br /> 15 and practices and courses of conduct set out below. <br /> 16 DEFENDANTS <br /> 17 4. Defendant BORETECH RESOURCE RECOVER ENGINEERING LLC, a limited <br /> 18 liability company, a business of unknown type of organization, is, and at all times relevant herein <br /> 19 was, engaged in the business of PLASTIC RECYCLING OPERATION, located at 1820 <br /> 20 INDUSTRIAL DRIVE, STOCKTON, CALIFORNIA. <br /> 21 5. Defendant JO H LEE, individually, is, and at all times relevant herein was, engaged in the <br /> 22 business of PLASTIC RECYCLING OPERATION, located at 1820 INDUSTRIAL DRIVE, <br /> 23 STOCKTON, CALIFORNIA. <br /> 24 6. Defendant JO H LEE, as an officer of BORETECH RESOURCE RECOVRY <br /> 25 ENGENEERING LLC, a limited liability company, is, and at all times relevant herein was, engaged <br /> 26 in the business of PLASTIC RECYCLING OPERATION, located at 1820 INDUSTRIAL DRIVE, <br /> 27 STOCKTON, CALIFORNIA. <br /> 28 7. Defendant JO H LEE dba BORETECH RESOURCE RECOVRY ENGENEERING LLC, <br /> -2- <br /> rrrr�rT-rrr� mr ♦i�im r+�ii i' Tir rT�mT��T LTi Iii iriT A A TITS IITTTTT'1 T)TT TTT .. <br />