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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 />a limited liability company, is, and at all times relevant herein was, engaged in the business of <br />PLASTIC RECYCLING OPERATION, located at 1820 INDUSTRIAL DRNE, STOCKTON, <br />CALIFORNIA. <br />8. Defendant ALICE KAO, individually, is, and at all times relevant herein was, engaged in <br />the business of PLASTIC RECYCLING OPERATION, located at 1820 INDUSTRIAL DRIVE, <br />STOCKTON, CALIFORNIA. <br />9. Defendant ALICE KAO, 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 />10. Defendant ALICE KAO dba BORETECH RESOURCE RECOVRY ENGENEERING <br />LLC, a limited liability company, is, and at all times relevant herein was, engaged in the business of <br />PLASTIC RECYCLING OPERATION, located at 1820 INDUSTRIAL DRIVE, STOCKTON, <br />CALIFORNIA. <br />11. Defendant PO HAO OU, individually, is, and at all times relevant herein was, engaged in <br />the business of PLASTIC RECYCLING OPERATION, located at 1820 INDUSTRIAL DRIVE, <br />STOCKTON, CALIFORNIA. <br />12. Defendant DOES ONE through TWENTY are connected and responsible for the acts <br />complained of below. Their real names are unknown at this time, and the People will amend this <br />Complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br />13 . Whenever in this Complaint reference is made to any act of Defendant, such allegation <br />shall be deemed to mean that Defendant and his officers, agents, employees, or representatives, did <br />or authorized acts while actively engaged in the management, direction, or control of the affairs of <br />said Defendant, and while acting within the course and scope of their duties. <br />14. All Defendants at all times acted as agents of one another. With regard to the conduct <br />and omissions alleged in this Complaint, each of the Defendants ratified the actions of the other <br />Defendants. <br />/// <br />-3- <br />