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1 1 4, Pursuant to Health and Safety Code section 25299.0 1,the Attorney General and <br /> 2 the Local Prosecutors may bring an action to enjoin any violation of Chapter 6.7 of Division 20 of <br /> 3 the Health and Safety Code(hereinafter**Chapter 6.7"), or for an order directing Coll) I C <br /> I p ian e with <br /> 4 Chapter 6.7 <br /> 5 5- Pursuant to Health acid Safety Code sections 25544 and 25516.1,the Attorney <br /> 6 General and the Local Prosecutors may bringan action for civil penalties for violations of Health <br /> 7 and Safety Code sections 23503.5.to 25505,inclusive, and sections 25.508 to 25-520,inclusive. <br /> .8; Pursuant to Health and Safety Code section 25516,the Local Prosecutors,when requested byan <br /> administering agency may bring an action to enjoin a violation of Chapter 6,95.6.f Division 20 of <br /> 9 i <br /> the Health,and Safety.Code (hereinafter"Chapter 6.,95'0.. Several admin-1stering agencies have, <br /> requested the Attorney General.and (fie Local Prosecutors.to bring an action to enJoin violations <br /> of Chapter 6,95, and to seek civil penalties for violations of the provisions of Chapte-r 6.95 that <br /> are under the jurisdiction of the agencies. <br /> 13 <br /> 6. Pursuant to Business and Professions Code sections 1.72013,. 1720 and 17206,the. <br /> 14 Attorney General and the Local Prosecutors may bring actions in the name of the People of the <br /> 15 State of California in a superior or court f6r an injunction against arty person.who engra es, ad <br /> 16 engaged,or proposes to engage in unfair competition and,for civil penalties for each act of unfair <br /> 17 competition. <br /> 19 7 Plaintiff brings this action without preJudico to any other action or claims which <br /> 19 Plaintiff may have based on separate, independent and unrelated violations arising out.of matters <br /> 20 or altogations that are not set forth in this Complaint. <br /> 21 DEFE NDANT WALRMART STORES, INC. <br /> 22 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 through affiliates in the State of California at the Wal-Mart and Sam's Club <br /> 25 facilities identified in Exhfbit A(hereinafter collectively referred to as"California Facilities"), <br /> 26 The California Facilities are located throughout California, and WalWMart's principal corporate <br /> ,27 office is in Bentonville, Arkansas. The People are informed and believe, and thereon allep, that <br /> 28 Wal.=Mart is the owner and/or operator of the California.Facilities. Wal-Mart sells hazardous <br /> 5 <br /> COMPLAINT FOR PERMAN)3NT INJUNCTION,CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />