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I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20' 21I 22 23 24 25 26 27 281 JURISDICTION AN VENUE 3. The defendants transact business within the County of San Joaquin and elsewhere throughout the State of California. The alleged violations of the law, hereinafter described, have been carried out within said San Joaquin County and elsewhere throughout the State of California. The alleged actions of the defendants and each of them, jointly and separately, as set out below, are in violation of the law and public policy of the State of California. Unless enjoined and restrained by an order of this court, the defendants will continue to retain the means to engage in unlawful action and practices and courses of conduct set out below. DEFENDANTS 4. Defendant BONFARE MARKETS, INC., a corporation, a business of unknown type of organization, is, and at all times relevant herein was, engaged in the business of GASOLINE SALES/MINI-MART, located at 15 E. GRANT LINE ROAD, TRACY, CALIFORNIA. 5. Whenever in this complaint reference is made to any act of defendants, such allegation shall be deemed to mean that defendants and their officers, agents, employees, or representatives, did or authorized acts while actively engaged in the management, direction, or control of the affairs of said defendants, and while acting within the course and scope of their duties. FIRST CAUSE OF ACTION VIOLATIONS OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. (UNDERGROUND STORAGE OF HAZARDOUS MATERIALS) 6. Plaintiff is informed and believes and based on such information and belief alleges that beginning at an exact date that is unknown to plaintiff, but within five (5) years prior to the filing of this complaint (CCP §338.1), defendants engaged in violated Health and Safety Code Chapter 6.7, including but not limited to: HAHOME1EANTOLMUMBONFARE. WPD 0)