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I be necessary to allege or prove at any stage of the proceeding that irreparable damage will occur 2 should the temporary restraining I , order.,preliminary injunction,or permanent injunction not be issued,- or that the rernedy at law is inadequate,and the temporary restraining order, preliminary 4 injunction, or permanent injunction shall issue without such allegations and without such proof. 5 24. The HWCL,in sections 25180.and25185,-authorizes the DTSC,,And properly 6 designated local health agencies and,unified program agencies,to enforce the standards codified 7 in Chapter 6.5 and the regulations adopted pursuant to the Health and Safety Code, andio. .8 conduct inspections. GENERAL ALLEGATIONS ,9 25. The People,and Wal�Mart entere,,d into a series of agreements to tall any.applicable siatuto of limitations. Asa result orthoso agreements, the period of time from January 15,2006, 1 12 through the date-.of the.filing orthe�.Complalnt herein, inclusive, (the"Tolling,Period"),will not be included in comVUting the time limited by any statute of limitations under the causes of action 13 against Wal--Marahat may arise out ofel'aims covered, by the tolling agreement. Tho8cclaims 14 include the claims that are brought in this action against Wal-Mart. 15 26, In March 2006,employees of the Wal-Mart store at 4940 Shawfine,St..in Son 16. Diego drove-a rental truck to Miramar Landfill and disposed of hazardous and universal wastes 17 from time store. Miramar Landfill is a.solid waste that is not authorized to accept IS, hazardous or universal wast4s for disposal. The items that the employees disp—osod included- 2.5 19 gallons of motor oil;transmission fluid;a 5 pound fire extinguisher;rechargeable batteries,;3 20poUndes of other batteries;and corrosive and flammable household chemicals. Investigation 21 revealed a store manager told the employees to dispose of the items from the customer return 22 counter at the landfill. 23 27: In April 2006,employees of the Wal-Mart store at 3412 College Ave. in San 24 Diego drove a rental truck to Miramar Landfill and disposed of hazardous and universal wastes 25 from the store. The items that the employees disposed included- 3 gallons of bleach;a remote 26 control with batteries; a water cooler element,and prohibited electronic waste consisting of a 27 DVD player. Investigation revealed the employees had been told by the managerto dispose,of 28 the items at the landfill., 9 CUMPLAtNT FOR PERMANENT INJUNCTfON,Cf VIL PI NAL AND OTHER UQUITABLE RELIEP