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2 <br />Gl <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />h•avani-Sari, and Tina Nunes Ober, Deputy District Attorneys; David W. Paulson, District <br />Attorney for the County of Solano, Lindsay D. Horvath, Deputy District Attorney; Birgit A. <br />Fladager, District Attorney for County of Stanislaus, Matthew C. Maclear, Deputy District <br />Attorney; Gregory Totten, District Attorney for the County of Ventura, Mitchell F. Disney, <br />Senior Deputy District Attorney; and Jeff W. Reisig, District Attorney for Yolo County, Larry <br />Barlly, Supervising Deputy District Attorney (collectively "Local Prosecutors"). <br />2. Pursuant to California Health and Safety Code sections 25145.4 and 25182, the <br />Attorney General and the Local Prosecutors may bring a civil action in the name of the People of <br />the State of California to enjoin any violation of Chapter 6.5 of Division 20 of the California <br />Health and Safety Code ("Chapter 6.5") and to seek civil penalties for violations of Chapter 6.5. <br />Pursuant to California Health and Safety Code sections 25516 and 25516. 1, the Local <br />Prosecutors and the Attorney General, respectively, may bring a civil action in the name of the <br />People of the State of California to enjoin any violation of California Heath and Safety Code <br />sections 25503.5 and 25505, inclusive, and/or sections 25508 to 25520, inclusive. <br />4. Pursuant to California Business and Professions Code sections 17203, 17204 and <br />17206, the Attorney General and the Local Prosecutors may bring a civil action in the name of the <br />People of the State of California to enjoin any person who engages, has engaged, or proposes to <br />engage in unfair competition, as defined in California Business and Professions Code section <br />17200, and for civil penalties for each act of unfair competition. <br />5. Plaintiff brings this action without prejudice to any other actions or claims which <br />Plaintiff may have based upon separate, independent and unrelated violations arising out of <br />matters or allegations that are not set forth in this Complaint. <br />DEFENDANTS <br />6. Defendant Target Corporation ("Target") is now, and at all times mentioned in this <br />Complaint was, a Minnesota corporation which does and did business in its own capacity and/or <br />through affiliates in the State of California at retail stores and distribution centers identified in <br />Exhibit A, which is incorporated herein by reference (collectively referred to as "Covered <br />Facilities"). Target handled hazardous materials and hazardous wastes at Covered Facilities <br />2 <br />id Pennanent Injunction, Civil Penalties and Other <br />Case No. RG09457686 <br />