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<br /> I any person who engages, has engaged, or proposes to engage in unfair competition, as defined in
<br /> 2 California Business and Professions Code section 17200, and to seek civil penalties for each act
<br /> 3 of unfair competition.
<br /> 4 5. Plaintiff brings this action without prejudice to any other action or claim which
<br /> 5 Plaintiff may have based on separate,independent and unrelated violations arising out of matters
<br /> 6 or allegations that are not set forth in this Complaint.
<br /> 7 DEFENDANT COSTCO WHOLESALE CORPORATION
<br /> g AND DEFENDANT'S FACILITIES
<br /> 9 6. Defendant Costco Wholesale Corporation(hereinafter"Defendant")is now, and at
<br /> 10 all times mentioned in this Complaint was,a Washington corporation, with its principal corporate
<br /> 11 offices located in Issaquah, Washington.
<br /> 12 7. At all times relevant,Defendant has owned or operated Costco Wholesale
<br /> 13 Corporation warehouses, depots,business centers, stores,tire service centers, and pharmacies in
<br /> 14 the State of California,including certain Costco Wholesale Corporation warehouses, depots,
<br /> 15 business centers, tire service centers, and pharmacies that had previously been owned and
<br /> 16 operated by Defendant and its subsidiaries, affiliates,predecessors and corporate parents
<br /> 17 (collectively"Defendant's Facilities"). A list of the locations of Defendant's Facilities that are
<br /> 18 owned or operated by Defendant as of April 27, 2012 is provided in Exhibit A, attached.
<br /> 19 8. The People are informed and believe and based thereon allege that at all times
<br /> 20 relevant hereto and as more fully alleged in paragraph 21,below,Defendant has stocked, stored
<br /> 21 and sold hazardous materials at and from Defendant's Facilities. These hazardous materials
<br /> 22 include,but are not limited to,pharmaceuticals and over-the-counter medications,bleaches,
<br /> 23 photoprocessing chemicals,pool chlorine and acids,batteries, electronic devices,mercury-
<br /> 24 containing lamps, ignitable liquids, aerosol products, oven cleaners and various other cleaning
<br /> 25 agents, automotive products,and other flammable, reactive,toxic and corrosive materials.
<br /> 26 Defendant also generated regulated quantities of hazardous waste at each of Defendant's
<br /> 27 Facilities as a result of various causes, including but not limited to, damage to containers, spills
<br /> 28 and releases of hazardous materials,pharmaceutical and pharmacy wastes, photo waste
<br /> 3
<br /> Complaint For Permanent Injunction,Civil Penalties And Other Equitable Relief
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