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• 0 0 <br />1 District Attorney of San Joaquin County, bring this action in the public interest and in the name of <br />2 THE PEOPLE OF THE STATE OF CALIFORNIA and hereby allege: <br />3 JURISDICTION AND VENUE <br />4 3. The Defendants transact business within the County of San Joaquin and elsewhere <br />5 throughout the State of California. The alleged violations of the law, hereinafter described, have been <br />6 carried out within said San Joaquin County and elsewhere throughout the State of California. The <br />7 alleged actions of the Defendants and each of them, jointly and separately, as set out below, are in <br />8 violation of the law and public policy of the State of California. Unless enjoined and restrained by an <br />9 order of this court, the Defendants will continue to retain the means to engage in unlawful action and <br />10 practices and courses of conduct set out below. <br />11 DEFENDANTS <br />12 4. Defendant BONFARE MARKETS, INC., a California corporation, a business of unknown <br />13 type of organization, is, and at all times relevant herein was, engaged in the business of GASOLINE <br />14 SALES/MINI-MART, located at 15 E. GRANTLINE ROAD, TRACY, CALIFORNIA. <br />15 5. Defendant BONFARE MARKETS, INC., a California corporation dba BONFARE <br />16 MARKET, a business of unknown type of organization, is, and at all times relevant herein was, <br />17 engaged in the business of GASOLINE SALES/MINI-MART, located at 15 E. GRANTLINE ROAD, <br />18 TRACY, CALIFORNIA. <br />19 6. Defendant JAGJEET S. KAPOOR, individually and as an officer of BONFARE <br />20 MARKETS, INC., a California corporation, is and at all times relevant herein was, engaged in the <br />21 business of GASOLINE SALES/MINI-MART, located at 15 E. GRANTLINE ROAD, TRACY, <br />22 CALIFORNIA. <br />23 7. Defendant JAGJEET S. KAPOOR, individually and as an officer of BONFARE <br />24 MARKETS, INC., a California corporation dba BONFARE MARKET, is and at all times relevant <br />25 herein was, engaged in the business of GASOLINE SALES/MINI-MART, located at 15 E. <br />26 GRANTLINE ROAD, TRACY, CALIFORNIA. <br />27 8. Defendant DOES ONE through FIFTY are connected and responsible for the acts <br />28 complained of below. Their real names are unknown at this time, and the People will amend this <br />2 <br />VERIFIED COMPLAINT <br />