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I be necessary to allege or prove at any stage of the proceeding that irreparable damage will occur 2 should the temporary restraining I , order.,preliminary injunction,or permanent injunction not be issued,- or that the rernedy at law is inadequate,and the temporary restraining order, preliminary 4 injunction, or permanent injunction shall issue without such allegations and without such proof. 5 24. The HWCL,in sections 25. 1 80.and.25185,.authorizes the DTSC,And properly 6 designated local health agencies and,unified program agencies,to enforce the standards codified 7 in Chapter 6,5 and the regulations adopted pursuant to the Health and Safety Code, and:io. .8 conduct inspections. GENERAL ALLEGATIONS .9 25. The People,and Wal�Martentered into a series of agreements to toll any.applicable '0 I. siatuto of limitations. Asa result of thoso Agreements, the period of time from January 15,2006, ll through the date-.of the.-filing or the�,Complaint herein, inclusive, (the"'rolling,Period"),will not be included in computing the time limited by any statute of limitations under the causes of action 13 against Wal-;-Mart.that May arise out ofelaims covered, by the tollingagree=nt- 'Mo8c claims 14 include the claims that are brought in this action against Wal-Mart. 15 26, In March 2006,employees of the Wal-Mart store at 4940 Shawfine,St..in Son 16. Diego drove-a rental truck to Miramar Landfill and disposed of hazardous and universal wastes 17 from the-. store.;, Miramar Landfill is a.solid waste landfill that is not authorized to accept IS, hazardous or universal wastes for disposal. The items that the employees disp—osod included- 2.5 19 gallons of motor oil;trarismission fluid;a 5 pound fire extinguisher;rechargeable batteries,;3 20poundes of other batteries;and corrosive and flammable household chemicals. Investigation 21 revealed a store manager told the employees to dispose of the items from the customer return 27 counter at the landfill. 23 27: In April 2006,employees of the Wal-Mart store at 3412 College Ave. in San 24 Diego drove a rental truck to Miramar Landfill and disposed of hazardous and universal wastes 25 from the store. The items that the employees disposed included- 3..gallons of bleach;a remote 26 control with batteries; a water cooler element,and prohibited electronic waste consisting of a 27 DVD player. Investigation revealed the employees had been told by the manager to dispose,of 28 the items at the landfill., 9 CUMPLAtNT FOR PERMANENT INJUNCTfON,Cf VIL PENALTfES AND OTHER EQUITABLE RELIEP