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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 />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />abso r bed with absorbent were transp(lrtcd to the return center by an unlicensed hauler and with o ut <br />a manifest a s required by law. <br />33. In September 2005, an inspection of tile Wal-Mart store at 479 McKinley Street in <br />Corona, Riverside County , revealed that s pills o fwaslc o i l were being c leaned with absorbent and <br />then thrown in the municipal trash. <br />34 . In April 2002, local officia ls in So lan o County , California received ,I citi zen report <br />of a child playing on a pile ofycllowish colored powder near the garden department at a Wal- <br />Mart sto re in Vacav ill e, Ca l iforn ia. The Deputy Agri culture Commissioner was di s patched and <br />o bserved piles o f multi-c o lo re d unkn o wn fertilizer ty pe subs tanc es and 10 m sa c k s o f ammo nium <br />s ulfate . Subsequent inve stigati o ns revealed that fo r a peri o d o f several years, the Vaca v ill e Wal- <br />Mart had failed to comply with California enviro nmental laws related to the sto rage, handling. <br />and disposal of hazardous waste and materials, namely fertilizers , pesticides, and herbicides sold <br />in its garden center. <br />3 5. In late 2005 , the Anomey General 's Office joined with the District Attorney s ' <br />offices in variou s counties in the State of Ca lifo rnia to coo rdinate inve s tigat ion of Wal-Mart. The <br />investigation focused on v iolations of Cali fomi a laws regarding ill e gal disposal , transportat io n , <br />an d storage of hazardou s wastes, as well as compliance with ha7.ardou s materia ls management <br />plan requirements for each Californ ia Facility. <br />3 6. As a result of the above-referenced inves ti gation, Plaintiff is informed and believes <br />and thereupo n a ll eges that Wa l-Mart has v iolate d pro vision s of the fo ll owing statutes, including <br />implementing regulati o ns as so ciated with e ach o f the statute s and any related penn it , rul e, <br />standard, or requirement issued or promulgated pursuant to these statutes, at Californ ia Facilities <br />within the t im e period applicable to this ac ti on: Chapter 6.5 of the Health and Safety Code, <br />secti o n 25 100 e1 seq., Chapl er 6.7 of the H ealth and Safety C ode , section 25280 et seq., and <br />Chapter 6.9 5 of th e He alth and Safety C o de , secti o n 2 5 500 et seq . <br />37 . Plaintiff is informed and be lie ve s and thereupon a llege s that Wal -Mart en g aged in <br />co nd uct o r fa i led to act in a manner that violated provision s o f the sta tutory and legal <br />requirements identified in the preceding paragraph, including but not limited to the following: <br />II <br />COMPLAINT FOR PERMANENT INJUNCTION , C IVI L PENALTIES AND OTHER EQ U ITAB LE RELIEF