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1 1 4, Pursuant to Health and Safety Code scotion 25299.0 1, the Attorney General and <br /> 2 the Local Prosecutors may bring an action to enjoin any violation of Chapter 6.7 of Division 20 of <br /> 3 the flealdi and Safety Code(hereinafter*-Chapter 6.7"), or for an order directingcompliance wi b <br /> It <br /> 4 Chapter 6.7 <br /> 5 5- Pursuant to Health and Safety Code sections 25514 and 25516.17 the Attorney <br /> 6 General and the Local Prosecutors may bringan action for civil penalties for violations of Health <br /> 7 and Safety Code sections 235.13.5.to 25505,inclusive, and sections 23508 to 25-520,inclusive. <br /> Pursuant to Health and Safbty Code section 255516,the Local Prosecutors,when requested by an <br /> administering agency, may bring an action to enjoin a violation of Chapter 6,95.of Division 20 of <br /> 9 <br /> the Health and Siafety.Codc (hereinafter"Chapter 6,951.. ge <br /> Several adlmmiste i g a acits have <br /> m rin <br /> requested the Attorney General.and (lie Local Prosecutors.to bring an action to enjoin violations <br /> 1.2 <br /> of Chapter 6,95, and to seek civil penalties for violations of the provi.s'ions of Cha.pt�r 6.95 that <br /> are under the jurisdiction of the agencies. <br /> 13 <br /> 6. Pursuant to Business and Proftssions Code sections 1,7203,17204,and 17206,the. <br /> 14 1 Attorney General and the Local Prosecutors may bring actions in the name of the People of the <br /> 15 State of California in a superior court f6r an injunction against any,person.who engages,.had <br /> 16 . engaged,.or proposes to engage in unfair competition and forcivilpenalties for each act of unfair <br /> 17 competition. <br /> 19 7 Plaintiff brings this action without prejudice to any other action or claims which <br /> 19 Plaintiff may have based on separate, independent and unrelated violations arising out.of matters <br /> 20 or al legations that are not set forth in this Complaint. <br /> 21 DEFE NDANT WALE MART STORES, INC. <br /> 22 8- Defendant Wal-Mart Stores, Inc. (hereinafter"Wal-Mart") is now and,at all times <br /> 23 mentioned in.this complaint was,a Delaware corporation that does and did business in its own <br /> 24 capacity and/or through affiliates in the State of California at.the Wal-Mart and Sam's Club <br /> 25 facilities identified in Exlitbit A(hereinafter collectively referred to as"California Facilities"), <br /> 26 The California Facilities are located throughout California, and Wal�Mart's principal corporate <br /> ,27 office is in Bentonville, Arkansas. The People are informed and believe, and thereon allep, that <br /> 28 Wal.=Mart is the owner and/or operator of the California.Facilities. Wal-Mart sells hazardous <br /> 5 <br /> COMPLAINT FOR PERMAN)3NT INJUNCTION,CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />