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I materials at the CaliformaFacilitics that are retail stores, including aerosol products, f6rtillZeTS. 2 ignitable liquids,paints,pesticides,pool chemicals,.and other flammable or corrosive materials. 3 Wal-Mart also generates quantities of hazardous waste at the California Facilities from spills and 4 releases cif hazar.d(ius.material-s,a m nd from customer returns-of hAzardous items. 5 Darendant Wal-Mart is, or at all times.rolevant to the claims in this coatplaint was, 6 legally responsible for compliance,with the provisions of the Health and Safety Code, includ ing Chapters 6.5,.6.7 and 6,95 of Division 20,at its California Facilities, The People are informed 7 and believe and:thereon allege that Wal-Mart is responsible for the operations of the Cali'forr►ia Facilities,that Wal-Mart'controls.the.hazardous materials and hazardous waste Tnana' ent 10 decisions at those California facilides,that Wal-Mart took actions that caused the violations 1 € alleged herein,and that Wal-Mart's authority,control and actions at those California Facilities and in conducting business in Calif6rnia are such that Wal-Mart could have taken action to 12 pre'ven-tthe violations.-alleged herein. 13 10. Wal-Mart a"Pb is -rson,"as.defifted in Healthand Safety Code section 2511 S. - : 14 Wal-Mart is a"busiaess,a'as,defined in lfemlth and Sa-faty Code section 25501, subdivision(d) 15 I I. In this Complaint when reforenee is.made to any act of Wal-Mart, smyh allegations 16 shall include acts.,of the.owwtiers, T1 dar cets directors agents,ompluytes, coMractorsi.affiliates, or 17 rellresentativos of Wal-Mart that supervise, control or direct its employees:and. agents-white [8 engaged in the-management,direction,operation or control of the aff irs of tho business .19 orgaiii on and did so while acting within the oo-urse and scope of e mplQymetit or agency noy of 20 WalMart_ 21 JURISDICTION AND VENUE 22 12. Venue is proper in this county pursuant to Health and Safety CO'de section:25183 23 in that certain of the violations alleged in the Complaint occurred in the County of San Diego and 24 that certain.other statewide violations alleged in the Co mplaintarerelated to such violations. 25 TIAS Court has Jurisdiction purtuant to.Article 6, section 10 oftheCalifornia Constitution. 2.6 MMORY ANDREGULATORY)3ACXG'ROUND V 13. The State of California has enacted a comprehensive statutory and regulatory 28 framework for the generation-, handling,treatment.,storage,transportation,and disposal of COMPLAINT FOR.PERMANENT fNJLJNCTfON,CIVIL PENALTIES AND OTHER EQU.fTABLE RELIEP