60 Day Notice 2019-01166

AG Number: 
2019-01166
Notice PDF: 
Date Filed: 
06/17/2019
Noticing Party: 
Consumer Advocacy Group, Inc.
Alleged Violators: 
Perfect Image
Perfect Image LLC
Ross Dress For Less, Inc.
Ross Stores, Inc.
Chemicals: 
Di(2-ethylhexyl)phthalate (DEHP)
Source: 
Dual Compartment Clear Handbag with Polymer Components

60-Day Notice Document

Settlement
AG Number:
2019-01166
Settlement PDF: 
Settlement Date:
02/10/2021
Case Name: 
CAG v. Ross Stores, Inc, et al
Court Name: 
Alameda County Superior Court
Court Docket Number: 
RG19034033
Plaintiff: 
Consumer Advocacy Group
Plaintiff Attorney: 
Yeroushalmi & Yeroushalmi
Defendant: 
Perfect Image, LLC.
Injunctive Relief: 
Perfect Image will not order or manufacture any Covered Products for sale into California with any component over 0.1% by weight (1,000 parts per million) DEHP or DINP. Covered Products ordered for manufacture prior to the Effective Date over 0.1% must be affixed with Proposition 65 compliant warnings.
*Non-Contingent Civil Penalty:
$ 47,440.00
Attorney(s) Fees and Costs:
$ 42,000.00
Payment in Lieu of Penalty:
$ 35,560.00  (Civil Penalty: one check payable to OEHHA in the amount of $35,580.00 (75%) and one check payable to CAG in the amount of $11,860.00 (25%). CAG will use the payment in lieu of the civil penalties for such projects and purposes related to environmental protection, worker health and safety, or reduction of human exposure to hazardous substances.)
Total Payments:
$ 125,000.00
Will settlement be submitted to court?
Will settlement be submitted to court?: 
Yes
Contact Name: 
Reuben Yeroushalmi
Contact Organization: 
Yeroushalmi & Yeroushalmi
Email Address:
admin@yeroushalmi.com
Address: 
9100 Wilshire Blvd., Ste 240W
City, State, Zip:
Beverly Hills, CA 90212
Phone Number:
(310) 623-1926
Comments: 
This Settlement is related to the following Complaint and AG Numbers: 19STCV38610: 2019-01348, 2019-01419 20STCV18693: 2019-01631, 2019-01651, 2019-01809, 2019-01867, 2019-02059 AG Notice Number (Not on a Complaint): 2020-01261
Judgment
AG Number:
2019-01166
Judgment PDF: 
Judgment Date:
06/17/2021
Settlement reported to AG: 
Mon, 02/10/2020
Case Name: 
CONSUMER ADVOCACY GROUP INC VS ROSS STORES, INC. et al
Court Name: 
Alameda County Superior Court
Court Docket Number: 
RG19034033
Plaintiff: 
Consumer Advocacy Group, Inc.
Plaintiff Attorney: 
Reuben Yeroushalmi
Defendant: 
Perfect Image, LLC
Injunctive Relief: 
After the Effective Date, Perfect lmage will not order for manufacture any Covered Products for sale in California with any component that contains DEHP or DINP in excess of 0.1% by weight (1,000 ppm). Any Covered Products that Perfect Image sells, distributes, or ships into California after the Effective Date that were ordered for manufacture prior to the Effective Date must contain a clear and reasonable warning, unless it contains no more than 0.1% by weight (1,000 ppm) DEHP or DINP. For Covered Products requiring a warning pursuant to Section 4.1.1 a warning statement shall constitute compliance with Proposition 65 with respect to the alleged exposure to DEHP or DINP.
*Non-Contingent Civil Penalty:
$ 47,440.00
Attorney(s) Fees and Costs:
$ 42,000.00
Payment in Lieu of Penalty:
$ 35,560.00  (One check payable to OEHHA in the amount of $35,580.00 (75%) and one check payable to CAG in the amount of $11,860.00 (25%). CAG will use the payment in lieu of the civil penalties for such projects and purposes related to environmental protection, worker health and safety, or reduction of human exposure to hazardous substances.)
Total Payments:
$ 125,000.00
Is Judgment Pursuant to Settlement?
Yes
Contact Name: 
Reuben Yeroushalmi
Contact Organization: 
Yeroushalmi & Yeroushalmi
Email Address:
admin@yeroushalmi.com
Address: 
9100 Wilshire Blvd., Ste 240 W
City, State, Zip:
Beverly Hills, CA 90212
Phone Number:
(310) 623-1926


* A non-contingent civil penalty is the civil penalty that must be paid pursuant to the settlement, regardless of future events or actions of the defendant. If a settlement includes a contingent penalty, the plaintiff should report the additional penalty amount when it becomes due.