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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 />17206 of the Business and Professions Code, to commence a civil <br />action to obtain an injunction and recover civil penalties for <br />violations of the Chapter 5 of Part 3 of Division 7 of the <br />Business and ;lrofessions Code. <br />6. Defendants, each of them, transact business within the <br />County of San Joaquin and elsewhere within the State of <br />California. The violations hereinafter described have been <br />carried out within San Joaquin County. The actions of the defen- <br />dants, and each of them, jointly and severally, as set out below, <br />are in violation of the law and public policy of the State of <br />California and are inimical to the rights and interests of the <br />general public. <br />7. Venue of this action in this County is mandated by Health <br />and Safety Code Section 25183. <br />DEFENDANTS <br />8. Defendant, W.R. GRACE AND COMPANY, dba as ST SERVICES, <br />(hereinafter referred to as "ST SERVICES") is now, and at all <br />times mentioned herein was engaged in the business of petroleum <br />storage and transfer at 2941 Navy Drive, Stockton, California, <br />95206. Defendant, ST SERVICES, is a wholly owned subsidiary of <br />W.R. GRACE AND COMPANY, which is a Connecticut Corporation doing <br />business in California. <br />9. The true names or capabilities, whether individual, cor- <br />porate, associate, or otherwise, of defendants ONE through ONE <br />HUNDRED are unknown to plaintitt who therefore sues such defen- <br />dants by such fictitious names. Plaintiff will amend this <br />complaint to show their true names and capacities when ascer- <br />3. <br />