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be necc$sary to allege or prove al any stage or the proceeding that irreparable damage will occur 2 s hould the temporary re strainin g order, preliminary injun c tion , or pennanent injunction n ot be 3 issued; or that the remedy at law is inadequate. and the te mporary restraining order, preliminary 4 injunction, or permanent injunction shall issue without such allegations and without such proof. 5 6 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 22 23 24. The HWCL. in section s 25180 and 25185, authori zes the DTSC, and properly designated loc al health agencies and unified program agenc ies, to enforce the s tandard s cod ified in Chapter 6.5 and the reg ulations ad opted pursuant to the Health and Safety Code , and to conduct in spect ions. 7--,. GENERAL A LLEGATIONS The People and Wal-Mart entered into a series of agreements to toll any applicable statute of limitations. As a re suh of these agreements, the period of time from January 15, 2006, throu g h the date of the filing of the Compl aint he rein. inclu s ive, (the "Tolling Peri o d "), will not be included in computing the time li m ited by any statute of limitati ons under the causes of action against Wal-Mart that may arise out of claims covered by the tolling agreement. Those claims includ e the cla im s that are brought in this action against Wal -Mart. 26. In March 2006, emp loyees of the \Val-Mart store al4940 Shawline St. in San Die go drove a rental truck to Miramar Landfill and disposed of hazard ous and universal wastes from the slore. Miramar Landfill is a sol id waste landfill that is not authorized to accept hazardous o r universal wastes for dis posal. The it ems that the employees disposed includ ed: 2.5 gallons of motor oi l ; transm issio n fluid; a 5 pound fire ext inguisher; rechargeable ba tt eries; 3 pounds of other batteries; and corrosive and flammable household chemica ls. Inv estigat ion revea led a store manager told the emp loyees to dispose of the items from the c ustomer re turn counter at the landfi ll . 27. In April 2006, emp loyees of the Wal-Mart store at 3412 College Avc. in San 24 Dicgo drove a rental tru ck to Miramar Landfill and disposed of hazardous and universal wastes 25 from the s tore. The items that the employees disposed included: 3 gallons of bleach; a remote 26 control w ith batteries; a water cooler element; and prohib it ed e lectronic waste consisting of a 27 DVD player. In vestigation revea led the employees had been told by the manager to dispose of 28 the items at the landfilL 9 CO MPLAINT FOR PERMAN EN T INJUNCTION, CIVIL PENALTI ES AND OTHER EQUITABLE RELI EF