b. 1 Encana has done and continues to do substantial fossil fuel product-related 2 business in California. Between 1997 and 2006, Encana owned and operated the Wild Goose 3 Storage underground natural gas storage facility in Butte County, California. In 2003, Encana 4 began transporting natural gas through a 25-mile pipeline from the Wild Goose Station to a PG&E 5 compressor station in Colusa County, California, where gas entered the main PG&E pipeline. 6 Encana invested in a 100 billion cubic foot expansion of the facility in 2004, bringing gas storage 7 capacity at Wild Goose to 24 billion cubic feet. 8 38. Apache Corporation a. 9 Apache Corporation is a publicly traded Delaware corporation with its 10 principal place of business in Houston, Texas. Apache is an oil and gas exploration and production 11 company, with crude oil and natural gas exploration and extraction operations in the United States, 12 Canada, Egypt, and in the North Sea. b. 13 During the time at issue, Apache extracted natural gas from wells developed 14 on approximately seven million acres of land held in the Canadian provinces of British Columbia, 15 Alberta, and Saskatchewan, and Apache did substantial fossil fuel product-related business in 16 California. Apache transported a substantial volume of the natural gas extracted from its Canadian 17 holdings to California, where it sold that gas to electric utilities, end-users, other fossil fuel 18 companies, supply aggregators, and other fossil fuel marketers. Apache directed sales of its natural 19 gas to California in addition to markets in Washington state, Chicago, and western Canada, to 20 intentionally retain a diverse customer base and maximize profits from the differential price rates 21 and demand levels in those respective markets. 22 23 39. Doe Defendants a. The true names and capacities, whether individual, corporate, associate, or 24 otherwise of Defendants Does 1 through 100, inclusive, are unknown to Plaintiff, who therefore 25 sues said Defendants by such fictitious names pursuant to California Code of Civil Procedure 26 Section 474. Plaintiff is informed and believes, and on that basis alleges, that each of the 27 28 SHER EDLING LLP COMPLAINT 24