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I throughout the State of California. The alleged violations of the law,hereinafter described,have 2 been carried out within said San Joaquin County and elsewhere throughout the State of California. 3 The alleged actions of the Defendants and each of them,jointly and separately, as set out below, are 4 in violation of the law and public policy of the State of California. Unless enjoined and restrained by 5 an order of this court,the Defendants will continue to retain the means to engage in unlawful action 6 and practices and courses of conduct set out below. 7 DEFENDANTS 8 4. Defendant BULK TRANSPORTATION, a California corporation, a business of unknown 9 type of organization, is, and at all times relevant herein was, engaged in the business of 10 TRANSPORTATION OF DRY AND LIQUID COMMODITIES, located at 3032 S. EL DORADO 11 STREET, STOCKTON, CALIFORNIA. 12 5. Defendant DOES ONE through TWENTY is connected and responsible for the acts 13 complained of below. Their real names are unknown at this time, and the People will amend this 14 complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. 15 6. Whenever in this Complaint reference is made to any act of Defendants, such allegation 16 shall be deemed to mean that Defendants and their officers, agents, employees, or representatives, i 17 did or authorized acts while actively engaged in the management, direction, or control of the affairs 18 of said Defendants, and while acting within the course and scope of their duties. 19 7. All Defendants at all times acted as agents of one another. With regard to the conduct and 20 omissions alleged in this Complaint, each of the Defendants ratified the actions of the other 21 Defendants. 22 FIRST CAUSE OF ACTION I 23 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. 24 (HAZARDOUS WASTE CONTROL ACT) I i 25 8. Plaintiff is informed and believes and based on such information and belief alleges that j I 26 beginning at an exact date that is unknown to Plaintiff, but within five(5)years prior to the filing of i 27 this Complaint(CCP §338.1),Defendants engaged in acts in violation of Health and Safety Code 28 §25100 et seq., including but not limited to the following: -2- VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF