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I absorbed with absorbent were transported to the return cantor by an unlicensed hauler and without <br /> 2 a manifest as required by law. <br /> I <br /> -1 33. In September 2005,an inspection of the NVakMart store at 479 McKinley Street in <br /> 4 Corona,Riverside,County, revealed that spills of waste oil were being, cleaned with absorbent and <br /> 5 then thrown in the municipal trash. <br /> 6 34, In April 2002, local officials in Solano County,California received a citizen report <br /> of a child playing on a pile of yellowish,colored,powder near the,garden department at a Wal- <br /> Mart store in Vacaville, Callromia. The Deputy.Agriculture. Commissioner was dispatched atid <br /> 9 observed piles of multi-colored unknown fertiliser type substances and torn sacks of ammonium <br /> 10 sulfate. Subsequent investigations revealed that for apariod of severalyears, the Vacaville Wal- <br /> 11 <br /> a.1-II Mart had failed to comply with California environmental laws related to the storage,handling, <br /> 12 and disposal of hazardous waste and,materjals, namely fontilizers, pesticides, arid herbicides sold <br /> in its garden ctritcr. <br /> I3 <br /> 35. In late 2,005, the Attommy General's Office joined with the District Attorneys' <br /> 14 offices in various counties in the.State oCaliforniaCaJifornia tc,coordinate investigation of Wal-Mar. The <br /> 15 investigation focused on violations of California laws regarding ifle�gal disposal,transportation, <br /> 16 and storage of hx/,ardous wastes, as well as compliance with hazardous materials management <br /> 17 <br /> plan requirements for each California rac-11ity. <br /> 18 <br /> 36. As a result of the above-referenced investigation,plaintiff 1 or 0 believes <br /> Naintiff i 9 inr m.� do d be i v <br /> 19 and thereupon alleges that Wat-Mart has violated-provisions of the following statutes, including <br /> 20 implementing regulations associated with each of the statutes and any related permit,rule, <br /> 21 standard, or requirement issued or promulgated pursuant to these statutes,at California Facilities <br /> 22 within the time period applicable to this action-. Chapter 6.5 ofthe Health and Safety Code, <br /> 23 section 25 100 et seq., Chapter 6.7 of the Health and Safety Code, section 25290 et seq., and <br /> 24 Chapter 6.95 of the Health and Safety Code,section 25500 et seq. <br /> 25 37 Plaintiff is informed and believes and thereupon alleges that Wal-Mart engaged in <br /> 26 conduct or failed to act in a manner that violated provisions of the statutory and legal <br /> 27 requirements identified in the preceding paragraph, including l ut not limited to the following: <br /> 28 <br /> it <br /> COMPLAINT FOR PERMANENT MUNCTION,CML PENALTMS AND OTHER EQUITABLE RELIEF <br />