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I JURISDICTION AND VENUE <br /> 2 3. The Defendants transact business within the County of San Joaquin and elsewhere <br /> 3 throughout the State of California. The alleged violations of the law,hereinafter described,have <br /> 4 been carried out within said San Joaquin County and elsewhere throughout the State of California. <br /> 5 The alleged actions of the Defendants and each of them,jointly and separately, as set out below,are <br /> 6 in violation of the law and public policy of the State of California. Unless enjoined and restrained by <br /> 7 an order of this court,the Defendants will continue to retain the means to engage in unlawful action <br /> S and practices and courses of conduct set out below. <br /> 9 DEFENDANTS <br /> 10 4. Defendant FLAG CITY ARCO AM/PM,a business of unknown type of organization,is, <br /> 11 and at all times relevant herein was,engaged in the business of GASOLINE STATION AND <br /> 12 CONVENIENCE STORE, located at 14931 N. FLAG CITY BLVD., LODI, CALIFORNIA. <br /> 13 5. Defendant FLAG CITY ARCO AND SUBWAY,a business of unknown type of <br /> 14 organization, is and at all times relevant herein was,engaged in the business of GASOLINE <br /> 15 STATION AND CONVENIENCE STORE, located at 14931 N. FLAG CITY BLVD., LODI, <br /> 16 CALIFORNIA. <br /> 17 ' 6. Defendant YOUSIF HALLOUM,individually and d.b.a. FLAG CITY ARCO AM/PM is, <br /> 18 and at all times relevant herein was,engaged in the business of GASOLINE STATION AND <br /> 19 CONVENIENCE STORE, located at 14931 N. FLAG CITY BLVD.,LODI, CALIFORNIA. <br /> 20 7. Defendant YOUSIF HALLOUM, individually and d.b.a. FLAG CITY ARCO AND <br /> 21 SUBWAY is, and at all times relevant herein was, engaged in the business of GASOLINE <br /> 22 STATION AND CONVENIENCE STORE, located at 14931 N. FLAG CITY BLVD., LODI, <br /> 23 CALIFORNIA. <br /> 24 8. Defendant GORDEV SINGH, individually and d.b.a. FLAG CITY ARCO AM/PM is,and <br /> 25 at all times relevant herein was,engaged in the business of GASOLINE STATION AND <br /> 26 CONVENIENCE STORE, located at 14931 N. FLAG CITY BLVD.,LODI, CALIFORNIA. <br /> 27 9. Defendant GORDEV SINGH,individually and d.b.a.FLAG CITY ARCO AND <br /> 28 SUBWAY is,and at all times relevant herein was,engaged in the business of GASOLINE <br /> -2- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />