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rr <br /> 1 17206 of the Business and Professions Code, to commence a civil <br /> 2 action to obtain an injunction and recover civil penalties for <br /> 3 violations of the Chapter 5 of Part 3 of Division 7 of the <br /> 4 Business and1rofessions Code. <br /> 5 6 . Defendants, each of them, transact business within the <br /> 6 County of San Joaquin and elsewhere within the State of <br /> 7 California. The violations hereinafter described have been <br /> 8 carried out within San Joaquin County. The actions of the def en- <br /> 9 dants, and each of them, jointly and severally, as set out below, <br /> 10 are in violation of the law and public policy of the State of <br /> 11 California and are inimical to the rights and interests of the <br /> 12 general public. <br /> 13 7 . Venue of this action in this County is mandated by Health <br /> 14 and Safety Code Section 25183 . <br /> 15 DEFENDANTS <br /> 16 8 . Defendant, W.R. GRACE AND COMPANY, dba as ST SERVICES , <br /> 17 (hereinafter referred to as "ST SERVICES" ) is now, and at all <br /> 18 times mentioned herein was engaged in the business of petroleum <br /> 1y: storage and transfer at 2941 Navy Drive, Stockton, California, <br /> 20 95206. Defendant , ST SERVICES , is a wholly owned subsidiary of <br /> 21 W.R. GRACE AND COMPANY, which is a Connecticut Corporation doing <br /> 22 business in California . <br /> 23 9 . The true names or capabilities , whether individual, cor- <br /> 24 porate, associate, or otherwise, of defendants ONE through ONE <br /> 25 HUNDRED are unknown to plaintitt who therefore sues such defen- <br /> 26 dants by such fictitious names . Plaintiff will amend this <br /> 27 complaint to show their true names and capacities when ascer- <br /> 28 <br /> 3 . <br />