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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 the said San Joaquin County and elsewhere throughout the State of <br /> 5 California. The alleged actions of the defendants and each of them,jointly and separately, asset <br /> 6 out below,are in violation of the law and public policy of the State of California. Unless <br /> 7 enjoined and restrained by an order of this court, the defendants will continue to engage in and <br /> 8 continue to retain the means to engage in the unlawful actions and practices set out below. <br /> 9 DEFENDANTS <br /> 10 4.Defendants STOCKTON CONGREGATIONAL HOME, dba PLYMOUTH <br /> I 1 SQUARE, are, and at all times relevant herein were, engaged in the business of APARTMENT <br /> 12 RENTAL and MANAGEMENT, located at 1319 NORTH MADISON STREET, STOCRTON, <br /> 13 CALIFORNIA. <br /> 14 5. Whenever thin this complaint reference is made to any act of defendants, such <br /> 15 allegations shall be deemed to mean that defendants and its officers,agents,employees,or <br /> 16 representatives, did or authorized acts while actively engaged in the management,direction, <br /> 17 control of the affairs of said defendant, and while acting within the course and scope of their <br /> IS duties. <br /> 19 6. All defendants at all times acted as agents for one another. With regard to the conduct <br /> 20 and omissions alleged in the Complaint, each of the defendants ratified the actions of the other <br /> 21 defendants. <br /> 22 FIRST CAUSE OF ACTION <br /> 23 VIOLATIONS OF HEALTH AND SAFETY CODE <br /> SECTION 25280 ET SEQ. (UNDERGROUND STORAGE OF <br /> 24 HAZARDOUS MATERIALS) <br /> 25 7. Plaintiff is informed and believes and based on such information and belief <br /> 26 alleges that beginning at an exact date that is unknown to plaintiff,but within five(5)years prior <br /> 27 to the filing of this complaint, defendants have violated Health and Safety Code Chapter 6.7, by <br /> 28 <br /> a:DEPI�HARED�F3IJP4YM0/ni SQUAREcamy2 <br />