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i <br /> i <br /> 1 D. PHILLIPS, District Attorney of the County of San Joaquin, <br /> 2 hereby allege that : <br /> 3 <br /> D.EE;ENUANTS <br /> 4 4 . Defendants t.ransac:t businoss within the County of San <br /> 5 Joaquin. Tho violations hereinafter. described have been carried j <br /> 6 out within San ,lozicluin County. <br /> 7 <br /> 5. Defendant SUMIDEN WIRE PRODUCTS CORPORATION, + <br /> 8 "SUMTOE:N" <br /> ( ) is now, and at a1.1. times mentioned herein, was a <br /> 9 � <br /> California Corporation engaged in the business of manufacture of <br /> 10 <br /> steel strand: with its principle place of business located at <br /> 11 <br /> 1412 rl rinai. Drive, Stockton, c:alifornia , a location within San ; <br /> 12 <br /> Joaquin County . <br /> 13 <br /> 6. Defendant J.R. SIMPLOT COMPAtIY, is now, and at all + <br /> 1.4 <br /> times mentioned herein, was a corporation engaged in the <br /> 15 <br /> bur;iness 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 compl,jint, reference is made to any act i <br /> 18 <br /> of the defendants, --;uc;h all.egal-ions :hall be deemed to mean that <br /> 19 <br /> the officers, directors, agents, employees, or representatives <br /> 20 � <br /> of said deferidarits 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 /> FIR^T CAUSE of ACTION <br /> 24 <br /> VIOLA'T'IONS Or IiEALTH AND SAFETY <br /> 25 <br /> COUr SECT':ONS 25100 et seq . <br /> 26 <br /> (Hazardous Waste Control Act) <br /> 27 <br /> t S . The rules and regulations issued under and pursuant to <br /> 23 <br /> R <br /> 2 ! <br />