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I PLAINTIFF, PEOPLE OF THE STATE OF CALIFORNIA ("People"), brings its <br /> 2 action by and through DEAN D. FLIPPO, District Attorney of Monterey County <br /> 3 ("Monterey D.A."), and by and through JAMES P. WILLETT, District Attorney of San <br /> 4 Joaquin County ("San Joaquin D.A."), and by and through STEVE COOLEY, District <br /> 5 Attorney of Los Angeles County ("L.A. D.A."), and by and through MICHAEL A. <br /> 6 RAMOS, District Attorney of San Bernardino County ("San Bernardino D.A."), <br /> 7 collectively referred to as "the District Attorneys," and hereby STIPULATE AS <br /> 8 FOLLOWS: <br /> 9 WHEREAS, LensCrafters, Inc. ("LensCrafters" or "Defendant") is an Ohio <br /> 10 corporation, with corporate offices located at 4000 Luxottica Place, Mason, Ohio. <br /> 11 LensCrafters is authorized to conduct business in and operates retail stores in the State of <br /> 12 California. <br /> 13 WHEREAS, as part of the lens finishing process in its retail stores, Defendant <br /> 14 utilizes a polycarbonate coating material which is applied to some optical lenses, if <br /> 15 specifically requested by customers. This coating is applied to an optical lens in a machine <br /> 16 that is specifically designed for such application, where it is then cured onto the lens by <br /> 17 ultraviolet (UV) light. A small amount of overspray results from the application process <br /> 18 and this excess material (several ounces) is collected in an enclosed, labeled container <br /> 19 within the machine. <br /> 20 WHEREAS, based on the potential ignitability and potential toxicity of the coating, <br /> 21 the coating waste generated by Defendant may exhibit characteristics of hazardous waste <br /> 22 pursuant to Title 22 of the California Codified Regulations, Sections 66261.21 and <br /> 23 66261.24. <br /> 24 WHEREAS, Defendant treats the liquid coating waste daily in its stores. <br /> 25 Defendant's treatment process involves curing several ounces of the coating waste by <br /> 26 polymerizing it into a solid through the application of UV light in a specially designed <br /> 27 machine. Defendant's previous procedure for disposing of this waste was to cure it each <br /> 28 day into a solid form under the UV light, and to then place it in the trash for disposal along <br /> -2- <br /> 324/017851-0005 CONSENT AGREEMENT AND STIPULATION FOR <br /> 645783.01 a09/27/05 ENTRY OF FINAL JUDGMENT <br />