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2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />.8; <br />9 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />19 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />,27 <br />28 <br />4, P&Suant to Health and Safety Code section 2529'9.01, the Attorney General and <br />the Local Prosecutors: may bring an action to enjoin any violation of Chapter 6.7 of Division 20 of <br />thollealth and Safety Code (hereinafter -Chapter 6.7"), or for an order directing contpliance with <br />Chapter 6.7 <br />5- Pursuant to Health and Safety Code sections 25544 and 25516. 1, the Attorney <br />General and the Local Prosecutors may bringan action for civil penalties for vioWions of Health <br />and Safety Code sections 235.13.5 .to 25505, inclusive, and sections 25.508 to 25-520, inclusive. <br />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 />the Health and Safety .Code (hereinafter "Chapter 6.950.. Several adin 11 istering agencies naics have <br />ni <br />requested the Attorney General. and the Local Prosecutors. to bring an action to enJoin violations <br />of Chapter 6,95, and to seek civil penalties for violations of the provi.s'ions of Chapte-r 6.95 that <br />are under the jurisdiction of the agencies. <br />6. Pursuant to Business and Professions Code sections 1,7203,17204, and 17206,, the. <br />Attorney General and the Local Prosecutors may bring actions in the, name of the People of the <br />State of California in a superior court f6r an injunction against arty person. who engrages had <br />engaged,. or proposes to engage in unfair competition and for civil penalties for each act of unfair <br />competition. <br />7 Plaintiff brings this action without preJudico to any other action or claims which <br />Plaintiff may have based on separate, independent and unrelated violations arising out.of matters <br />or altogations that are not set forth in. this Complaint. <br />DEFENDANT WAL-MART STORES, INC. <br />8- Defendant Wal-Mart Stores, Inc. (hereinafter "Wal-Mart") is now and, at all times <br />mentioned in. this complaint was, a Delaware corporation that does and did business in its own <br />capacity and/or through affiliates in the State of California at. the Wal-Mart and Sam's Club <br />facilities identified in Exhfbit A (hereinafter collectively referred tows "California Facilities"), <br />The California Facilities are located throughout California, and WalWMart's principal corporate <br />office is in Bentonville, Arkansas. The People are informed and believe, and thereon allege, that <br />Wal.=Mart is the owner and/or operator of the California. Facilities. Wal-Mart sells hazardous <br />I <br />COMPLAINT FOR PERM AN13NT INJUNCTION, CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />