Laserfiche WebLink
1 D. PHILLIPS, District Attorney of the County of San Joaquin, <br /> 2 hereby allege that: <br /> 3 DEFENDANTS <br /> 4 4 . Defendants transact business within the County of San <br /> 5 Joaquin. The violations hereinafter described have been carried <br /> 6 out within San Joaquin County. <br /> 7 5. Defendant SUMIDEN WIRE PRODUCTS CORPORATION, <br /> 8 ("SUMIDEN") is now, and at all times mentioned herein, was a <br /> 9 <br /> California Corporation engaged in the business of manufacture of <br /> 1fl <br /> steel strands with its principle place of business located at <br /> 11 <br /> 1412 E1 Pinal Drive, Stockton, California, a location within San <br /> 12 <br /> Joaquin County. <br /> 13 6. Defendant J.R. SIMPLOT COMPANY, is now, and at all <br /> 14 times mentioned herein, was a corporation engaged in the <br /> 15 <br /> business of fertilizer production with a manufacturing facility <br /> 16 <br /> in Lathrop, a location within San Joaquin County. <br /> 17 <br /> 7 . When, in this complaint, reference is made to any act <br /> 18 <br /> of the defendants, such allegations shall be deemed to mean that <br /> 19 <br /> the officers, directors, agents, employees, or representatives <br /> 20 <br /> of said defendants did, or authorized, such acts, and did so <br /> 21 <br /> while acting within the course and scope of their employment or <br /> 22 <br /> agency. <br /> 23 <br /> FIRST CAUSE OF ACTION <br /> 24 <br /> VIOLATIONS OF HEALTH AND SAFETY <br /> 25 <br /> CODE SECTIONS 25100 et seq. <br /> 26 <br /> (Hazardous Waste Control Act) <br /> 27 <br /> 8 . The rules and regulations issued under and pursuant to <br /> 28 <br /> 2 <br />