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I JURISDICTION AN[) VENITE <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 said San Joaquin County and elsewhere throughout the State of California. <br /> 5 The alleged actions of the Defendants and each of them,jointly and separately,as set out below, are <br /> 6 in violation of the law and public policy of the State of California. Unless enjoined and restrained by <br /> 7 an order of this court, the Defendants will continue to retain the means to engage in unlawful action <br /> 8 and practices and courses of conduct set out below. <br /> 9 DEFENDANTS <br /> 10 4. Defendant CHEROKEE LANE SERVICE STATION,a business of unknown type of <br /> 11 organization, is,and at all times relevant herein was,engaged in the business of GASOLINE <br /> 12 STATION,located at 900 S. CHEROKEE LANE, LODI,CALIFORNIA. <br /> 13 5. Defendant CHEROKEE SERVICE STATION,a business of unknown type of <br /> 14 organization, is,and at all times relevant herein was,engaged in the business of GASOLINE <br /> 15 STATION,located at 900 S. CHEROKEE LANE, LODI,CALIFORNIA. <br /> 16 6. Defendant DIDAR SINGH RANDHAWA, individually and d.b.a. CHEROKEE LANE <br /> 1.7 SERVICE STATION is,and at all times relevant herein was,engaged in the business of GASOLINE <br /> 18 STATION,located at 900 S. CHEROKEE LANE, LODI,CALIFORNIA. <br /> 19 7. Defendant DIDAR SINGH RANDHAWA, individually and d.b.a. CHEROKEE <br /> 20 SERVICE STATION is,and at all times relevant herein was, engaged in the business of GASOLINE <br /> 21 STATION,located at 900 S. CHEROKEE LANE, LODI,CALIFORNIA. <br /> 22 8. Defendant DOES ONE through TWENTY are connected and responsible for the acts <br /> 23 complained of below. Their real names are unknown at this time, and the People will amend this <br /> 24 Complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br /> 25 9. Whenever in this Complaint reference is made to any act of Defendants,such allegation <br /> 26 shall be deemed to mean that Defendant,-,and their officers, agents,employees, or representatives, <br /> 27 did or authorized acts while actively engaged in the management, direction, or control of the affairs <br /> 28 of said Defendants,and w1ii1e acting within the course and scope of their duties. <br /> ....................... ..................... ................-I.....".......... -2- .... .................. ..... ....... <br /> VERIFIED COMPLAINT FOR.INJUNCTION,CIVIL PENALTIES,.AND OTHER RELIEF <br />