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I name of the People of the State of California to enjoin any violation of Chapter 6.5 of Division <br /> 2 20 of the California Health and Safety Code(hereinafter, "Chapter 6.5")and to seek civil <br /> 3 penalties for violations of the provisions of Chapter 6.5. <br /> 4 2. Pursuant to California Health and Safety Code section 25514,the Attorney <br /> 5 General,the District Attorneys and their representatives,on behalf of the People of the State of <br /> 6 California,may bring an action for civil penalties for violations of California Health and Safety <br /> 7 Code sections 25503.5 to 25505,inclusive or sections 25508 to 25520,inclusive. <br /> 8 3. Pursuant to California Health and Safety Code section 25516,the Attorney <br /> 9 General,the District Attorneys and their representatives,may bring an action to enjoin a <br /> 10 violation of Chapter 6.95 of Division 20 of the California Health and Safety Code(hereinafter <br /> 11 "Chapter 6.95"). <br /> 12 4. Pursuant to California Business and Professions code sections 17203, 17204,.and <br /> 13 17206,the Attorney General,the District Attorneys and their representatives may bring actions <br /> 14 in the name of the People of the State of California in a Superior Court for an injunction against <br /> 15 any person who engages,has engaged,or proposes to engage in unfair competition and for civil <br /> 16 penalties for each act of unfair competition. <br /> 17 5. This Complaint addresses Kmart Corporation's hazardous-waste and hazardous- <br /> 18 materials handling practices at and by its retail stores in the State of California. Plaintiff brings <br /> 19 this action without prejudice to any other action or claims which may exist that are not alleged <br /> 20 in this Complaint. <br /> 21 DEFENDANT 3 <br /> 22 6. Defendant Kmart Corporation("Defendant"),is a Michigan Corporation. At all <br /> 23 times relevant hereto,Defendant was a mass-merchandiser conducting retail sales business in <br /> 24 the State of California at the facilities identified in Exhibit A,incorporated herein by this <br /> 25 reference. The facilities listed in Exhibit A are collectively referred to as the"Covered <br /> 26 Facilities." <br /> 27 7. The Defendant,at all times relevant to the claims in this Complaint,was legally s <br /> 28 responsible for compliance with the provisions of the California Health and Safety Code <br /> -2- <br /> COMPLAINT FOR IN.IIINCTION,CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />