Laserfiche WebLink
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 />27 <br />28 <br />materials at the California Facilities that are retail Stores, including aerosol products, f6rtillZeTS, <br />ignitable liquids-, paints, pesticides, pool chemic als,. and other flammable or corrosive materials. <br />Wal-Mart also generates quantities of hazardous waste at the California Facilities from spills and <br />releases of hazardousmaterials, and from customereurnS of h rdous items. <br />Darbridant Wal-Mart is, or at all times rolevant to the claims in this complaint was, <br />legally responsible for compliance withAlic provisions of thel-lealth. end Safety Code, including <br />Chapters 6.5,.6.7 and 6,95 of Division 201, at its Califomia Rarcilities, The People are informed <br />and believe and .Cher wn allege. that Wal-Mart is responsible fbr the operations of the Californ" <br />]a <br />1<a0trities, that Wal_martcoairols the -hazardous materials and hazardous waste manag <br />gertient <br />decisions at those California Facilities, that Wal-Mart 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 />pre'ven-tthe violations.,atteaed herein. <br />n . alth anSafet d Codc section 2511 S. <br />�d fhied i He. <br />10. as' 'e <br />Wal-Mart is:a "business," asAned in Health d e and Safety Code section 25501, subdivision (d) <br />I f. In thisConmplamnt when ,re!e,rence_is.made to -any act of Wal-Mart., such allegations <br />shall include acts., ofthe.owners, dffioet's4imotots, agents, employms, or <br />representatives of Wal-Mart that supervise, control or direct its employees,,and agents white <br />engaged in the -management, direction., operation or control of the aff irs of tho business <br />organization and did so while acting within the oo-urse and scope of employment or 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. alleged in the Complaint are related to such violations. <br />TIAS Court has jurisdJotion pursuant to Article 6, section 10 ofthe California Constitution. <br />STAMORY - -AND REGULATOW BACKGROUND <br />13. The State of Californi'a has enacted a comprehensive statutory and regulatory <br />framework for the generation-, handling, treatment., storage, transportation, and disposal of <br />COMPLAINT FOR. PERMANENT INJUNC I VON, CIVIL PENALTIES AND OTHER EQUITABLE RELIEP <br />