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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />from statutory language of the State of California, specifically Health and Safety Code sections <br />25182, 25189(d), and 25189.1, Health and Safety Code sections 25515, 25515.6, 25515.7, and <br />25515.8, Fish and Game Code sections 5650 and 5650.1, and Business and Professions Code <br />sections 17204 and 17206. <br />2. THE PEOPLE OF THE STATE OF CALIFORNIA, by and through TORI VERBER <br />SALAZAR, District Attorney of San Joaquin County, bring this action in the public interest and in <br />the name of THE PEOPLE OF THE STATE OF CALIFORNIA and hereby allege: <br />JURISDICTION AND VENUE <br />3. The Defendant transacts business within the County of San Joaquin and elsewhere <br />throughout the State of California. The alleged violations of the law, hereinafter described, have <br />been carried out within said San Joaquin County and elsewhere throughout the State of California. <br />The alleged actions of the Defendant and each of them, jointly and separately, as set out below, are in <br />violation of the law and public policy of the State of California. Unless enjoined and restrained by <br />an order of this court, the Defendant will continue to retain the means to engage in unlawful action <br />and practices and courses of conduct set out below. <br />DEFENDANTS <br />4. Defendant BORETECH RESOURCE RECOVER ENGINEERING LLC, a limited <br />liability company, a business of unknown type of organization, is, and at all times relevant herein <br />was, engaged in the business of PLASTIC RECYCLING OPERATION, located at 1820 <br />INDUSTRIAL DRIVE, STOCKTON, CALIFORNIA. <br />5. Defendant JO H LEE, individually, is, and at all times relevant herein was, engaged in the <br />business of PLASTIC RECYCLING OPERATION, located at 1820 INDUSTRIAL DRIVE, <br />STOCKTON, CALIFORNIA. <br />6. Defendant JO H LEE, as an officer of BORETECH RESOURCE RECOVRY <br />ENGENEERING LLC, a limited liability company, is, and at all times relevant herein was, engaged <br />in the business of PLASTIC RECYCLING OPERATION, located at 1820 INDUSTRIAL DRIVE, <br />STOCKTON, CALIFORNIA. <br />7. Defendant JO H LEE dba BORETECH RESOURCE RECOVRY ENGENEERING LLC, <br />-2- <br />