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2 <br />4 <br />6 <br />.7 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />[8 <br />.19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />2.5- <br />2.6 <br />)7 <br />28 <br />materials at the California Facilities that are retail stores, including aerosol products, f6rtillZeTS, <br />ignitable liquids, paints, pesticides, pool chemicals,. and other flammableor corrosive materials. <br />Wal-Mart also generates quantities of hazardous waste at the California Facilities from spills and <br />releases of hazardous materials, and from customer returns of hazardous items. <br />Defendant Wal-Mart is, or at all times rolevant to the claims in this coatplaint was, <br />legally responsible for compliance, with the provisions of the Health and Safety Code, including <br />Chapters 6.5,.6.7 and 6,95 of Division 20, at its California Rarcilities, The People are informed <br />and believe and: thereon allege that Wal-Mart is responsible for the operations of the Califorr►ia <br />Paoilides, that WaWart coriirolsthe.hazardous materials and hazardous waste manag <br />enient <br />decisions at those Call torn-JaFacil ides, that Wal- art took actions that caused the violations <br />alleged herein, and that Wal -Mart's authority, control and actions at those California Facilities <br />and in conducting business in Calif6rnia are such that Wal-Mart could have taken action to <br />prevent the violations: alleged herein. <br />10. Wal-mart.is a:'Ipbrson,"as. defifted in Healthand Safety Code section 2511 S. <br />Wal-Mart is a "busiaess;a' as defined in :health and Safaty Code section 25501, subdivision (d) <br />I I. In this Complain' t when reforenee is.made to any act of Wal-Mart, smyh allegations <br />shall include acts of the owners, dfftcet�s,,&ectors,mpluyt tractorsi affli I Wer <br />e es, <br />representatives of Wal-Mart that supervise, control or direct its employees: and. agents-wbile <br />engaged in the -management, direction, operation or control of the aff irs of tho business <br />orgaii� on and di so while acting within the oo-urse and scope of e mplQymetit or <br />izati �d agency of <br />Wal -Mart - <br />JURISDICTION AND VENUE <br />12. Venue is proper in this county pursuant to Health and Safety Co'de section: 25183 <br />in that certain of the violations alleged in the Complaint occurred in the County of San Diego and <br />that certain -other statewide violations al logod in the Complaint aro related to such violations. <br />TIAS Court has Jurisdiction pursuant to. Article 6 section 10 of'th e C'alif'ornia Constitution. <br />_ <br />MMORY ANDREGULATORY )3ACXGROUND <br />13. The State of California has enacted a comprehensive statutory and regulatory <br />framework for the generation-, handling, treatment., storage, transportation, and disposal of <br />COMPLAINT FOR. PERMANENT INJUNCTION, CIVIL PENALTIES AND OTHER EQIJITA13LE RELIEF <br />