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4 <br />5 <br />6 <br />7 <br />.8 <br />,9 <br />11 <br />13 <br />14 <br />15 <br />16. <br />17 <br />18 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />Eye necessary to allege or prove at any stage of the proceeding that irreparable damage will occur <br />should the temporary restraining order, preliminary injunction, or permanent injunction not be <br />issued,- or that the rernedy at law is inadequate, and the temporary restraining order, preliminary <br />inj u <br />. unction, or permanent injunction shall issue without such allegations and without such proof. <br />24. The HWCL, in sections 25180.and25185, authorizes the DTSC,,And properly <br />designated local health agencies and, unified program agencies, to enforce the standards, codified <br />in Chapter 6.5 and the regulations adopted pursuant to the Health and Safety Code, andio. <br />conduct inspections. <br />GENERAL ALLEGATIONS <br />25. The People, and Wal�Mart entered into a series of agreements to tall any applicable <br />statute of limitations. Asa result orthoso agreements, the period of time from January 15,2006, <br />through the date-. of the. filing orthe�.Complalnt herein, inclusive, (the "Tolling Period"), will not <br />be included in comVdting the tit-fte limited by any statute of limitations under the causes of action <br />against Wat-Mart that may arise out ofel'aims covered . by the toll ingagree=nt- 'ffio8c claims <br />include the claims that are brought in this action against Wal-Mart. <br />26, In March 2006, employees of the Wal-Mart store at 4940 Shawfine, St.. in Son <br />Diego drove -a. rental truck to Miramar Landfill and disposed of hazardous and universal wastes <br />from the store. Miramar Landrill isa.solid wastalan,dTill that is not authorized to accept <br />hazardous or universal wastes for disposal. The items. that the employees disposed included- 2.5 <br />gallons of motor oil; transmission fluid; a 5 pound fire extinguisher; rechargeable batteries; 3 <br />pounds of other batteries; and corrosive and flammable household chemicals. Investigation <br />revealed a store manager told the employees to dispose of the items from the customer return <br />counter at the landfill. <br />27: in April 2006, employees of the Wal-Mart store at 3412 College Ave. in San <br />Diego drove a rental truck to Miramar Landfill and disposed of hazardous and universal wastes <br />from the store. The items that the employees disposed included- 3..gallons of bleach; a remote <br />control with batteries; a water cooler element, and prohibited electronic waste consisting of a <br />DVI)player. Investigation revealed the employees had been told by the managerto dispose of <br />the items at the landfill., <br />N <br />CUMPLAWT FOR PERMANENT INJUNCTfON, Cf VIL PI NALTfES AND OVIER Int UITA:B:LE R E -LIEF <br />