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U 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21. Health and Safety Code section 25516.2 provides that in civil actions brought pursuant to Chapter 6.95 in which an injunction or temporary restraining order is sought, it is not necessary to allege or prove at any stage of the proceeding that irreparable damage will occur should the temporary restraining order, preliminary injunction, or permanent injunction not be issued; or that the remedy at law is inadequate, and the temporary restraining order, preliminary injunction, or permanent injunction shall issue without such allegations and without such proof. GENERAL ALLEGATIONS 22. At all times relevant hereto and continuing from and after the date of filing of this Complaint, Defendants owned and/or operated, and continue to own and/or operate, over 180 Covered Facilities throughout California, including retail stores and regional distribution centers. Defendants, and each of them, handle at the Covered Facilities enormous volumes of hazardous materials, including but not limited to, bleaches, pool chlorine and acids, pesticides, fertilizers, paints and varnishes, lamp oil and other ignitable liquids, aerosol products, oven cleaners and various other cleaning agents, automotive products and solvents, and other flammable and corrosive materials. Most of those hazardous materials are sold to the public in the ordinary course of business. However, at all times relevant hereto and continuing from and after the date of filing of this Complaint, hazardous materials handled by Defendants at the Covered Facilities were and are rendered unsalable and unusable for their intended purpose as the result of spillage, expiration of sell -by dates, contamination, damage to containers or labeling, and other causes, and must be handled and disposed of as hazardous waste in compliance with the HWCL. 23. At all times relevant to this Complaint; Defendants, and each of them, are and were responsible for the operation of the Covered Facilities in California. At all times relevant to this Complaint, Defendants, and each of them, were aware of and conducted, approved and/or controlled the hazardous materials, medical waste, and hazardous waste management activities at the Covered Facilities. At all times relevant to this Complaint, Defendants' actions and/or omissions, as part of a continuing course of conduct, are or were the legal cause of the violations alleged herein, and Defendants, and each of them, reasonably could have taken action to prevent the unlawful actions and/or omissions. and Permanent Case NQ. RG Relief