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2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />II <br />12 <br />13 <br />14 <br />I S <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />4. Pur suant to Health and Safety Code section 25299.0 I, the Attorney General and <br />th e Local Pro se cut ors may bring an action to enjoin any violation of Chapler 6.7 of Div is io n 20 of <br />the Heal th and Safety Code (hereinafter "Chapter 6.7"), or for an order directing com pliance with <br />Cha pter 6.7. <br />5 . Pursuant to Health and Safety Code sections 255 14 and 25516.1, th e Attorney <br />Genera! and the Local Prosecutors may bring an action for civil penalties for violations of Health <br />and Safety Code sections 25503.5 to 25505, inclusive , and sections 25508 to 25520 , inclusive. <br />Pursuant to Health and Safety Code section 25516, the Local Prosec utors, when requested by an <br />administering agency, may bring an aClion (0 enjoin a v io lation of Chapler 6.95 of Div is io n 20 o f <br />the He a lth and Safety Codc (hereinafter ';Chapte r 6.95"). Several administering agencies have <br />requested the Attomey (ienera! and the Local Pr osec utors to bring an action to enjoin v iolat ion s <br />of Chapter 6.95, and to see k civil penaltics for violations of the provisions of Chapter 6.95 that <br />are under the juri sd icti on of the agencies. <br />6. Pursua nt to Bu s ine ss and Pr ofessions Code secti ons 17203, 17204, and 17206, the <br />Attorney General and the Local Pro secut ors ma y bring actio ns in the name of the People o ftn e <br />State of California in a su perior court for an injunction against any person who engages , had <br />engaged, or proposes to engage in unfair competition and for civil penalties for each act of unfair <br />competi tion. <br />7 . Plaintiff brings this action without prejudice to an y other action or cl aims which <br />Plaintiff may have based on separate , independenr and unrclated vio lati ons arising out of matters <br />or allegations that are not set forth in this Complaint. <br />DEFENDANT WAL-MART STORES, INC. <br />8. Defendant Wal-Mart Stores, Inc. (hereinafter "Wal-Mart") is now and, at all times <br />23 mentioned in this complaint was, a Delaware corporation that does and did business in its own <br />24 capacity and/or thro ugh affiliates in the State of California at the Wal-Mart and Sam 's C lub <br />25 facilities identified in Exhibit A (hereinafter collectively referred to as "Ca lifornia Facil ities"). <br />26 The California facilities arc located throughout California, and Wal-Mart's principal co rporate <br />27 office is in Bentonville, Arkansas. The People are infonned and believe, and thereon allege, that <br />28 Wal-Mart is the owner andlor operator of the California Facilities. Wal-Mart sells hazardous <br />5 <br />COMPLAINT FOR PERMANENT INJUNCTION , C IVIL PENALTIES AND OTHER EQUITABLE RELIEF