60 Day Notice 2019-01868

AG Number: 
2019-01868
Notice PDF: 
Date Filed: 
10/03/2019
Noticing Party: 
Consumer Advocacy Group, Inc.
Alleged Violators: 
dd's Discounts
Premier Foods Group Ltd
Aci Brands
Ross Stores, Inc.
Ross Dress For less, Inc.
dd's Discounts
Ross Stores, Inc. dba dd's Discounts
Ali & Dax
Aci Brands Inc.
Chemicals: 
Di(2-ethylhexyl)phthalate (DEHP)
Source: 
Plastic Cosmetic Case

60-Day Notice Document

Supplemental Complaint
AG Number:
2019-01868
Complaint PDF: 
Date Filed:
05/04/2023
Case Name: 
Consumer Advocacy Group, Inc v. Ross Stores, Inc.
Court Name: 
Los Angeles County Superior Court
Court Docket Number: 
20STCV03564
Plaintiff: 
Consumer Advocacy Group, Inc.
Plaintiff Attorney: 
Reuben Yeroushalmi
Defendant: 
Ross Stores, Inc., dba DD's Discounts
Type of Claim: 
Failure to Warn
Toxic-Tort
Relief Sought: 
Warning
Civil Penalty
Injunction
Contact Name: 
Reuben Yeroushalmi
Contact Organization: 
Yeroushalmi & Yeroushalmi Law Firm
Email Address:
Address: 
9100 Wilshire Blvd 240w
City, State, Zip:
Beverly Hills, CA 90212
Phone Number:
(310) 623-1926
Comments: 
Complaint also pertains to AG # 2019-01629, 2019-01875, 2019-02082, 2019-01648, 2019-01782, 2019-01762, 2019-01832, 2019-01029, 2019-01508, 2019-01733, 2018-01443, 2019-01234, and 2018-01534
Civil Complaint
AG Number:
2019-01868
Complaint PDF: 
Date Filed:
01/28/2020
Case Name: 
CAG v. Ross Dress for Less et al.
Court Name: 
Los Angeles County Superior Court
Court Docket Number: 
20STCV03564
Plaintiff: 
Consumer Advocacy Group, Inc.
Plaintiff Attorney: 
Reuben Yeroushalmi
Defendant: 
Ross Dress for Less, Inc.
Ross Stores, Inc.
Ross Procurement, Inc.
Type of Claim: 
Failure to Warn
Relief Sought: 
Warning
Civil Penalty
Contact Name: 
Reuben Yeroushalmi
Contact Organization: 
Consumer Advocacy Group, Inc.
Email Address:
Address: 
9100 Wilshire Blvd., Suite 240W
City, State, Zip:
Beverly Hills, CA 90212
Phone Number:
310-623-1926
Comments: 
Please note that this Complaint also includes the following notices: -2019-01875 -2019-01629 -2019-01027 -2019-01833 -2019-01803 -2019-02005
Corrected Settlement
AG Number:
2019-01868
Settlement PDF: 
Settlement Date:
06/21/2023
Case Name: 
Consumer Advocacy Group, Inc v. Ross Dress for Less, Inc.
Court Name: 
Los Angeles County Superior Court
Court Docket Number: 
20STCV03564
Plaintiff: 
Consumer Advocacy Group, Inc.
Plaintiff Attorney: 
Reuben Yeroushalmi
Defendant: 
Ross Stores, Inc.
Injunctive Relief: 
3.1) After the Effective Date, Ross shall not order any Covered Products for sale into California, with any component that contains the Listed Chemical(s) in excess of 0.1% (1,000 parts per million) by weight. 3.2) Any Covered Products that Ross sells, distributes, or ships into California after the Effective Date that were ordered prior to the Effective Date, must contain a clear and reasonable warning, consistent with 27 CCR section 25600 et seq., unless it contains no more than 0.1% by weight (1,000 ppm) of the Listed Chemical(s). Any warnings provided pursuant to this Section 3.2 shall be affixed to the packaging of, or directly on, or attached to the Covered Products, and be prominently placed with such conspicuousness as compared with other words, statements, designs, or devices as to render it likely to be read and understood by an ordinary individual under customary conditions before purchase or use. The Parties agree that the following warning shall constitute compliance with Proposition 65 with respect to the Listed Chemical in the Covered Products for any Covered Products that Ross sells, distributes or ships into California after the Effective Date that contains the Listed Chemical(s) in excess of 0.1% (1,000 parts per million) by weight: 3.3) For Products containing DEHP: WARNING: This product can expose you to chemicals including Bis(2-ethylhexyl) phthalate (“DEHP”), which is known to the State of California to cause cancer and birth defects or other reproductive harm. For more information go to www.P65Warnings.ca.gov. or 3.4 For Products containing DINP: WARNING: This product can expose you to chemicals including Diisononyl Phthalate (“DINP”), which is known to the State of California to cause cancer. For more information go to www.P65Warnings.ca.gov 3.5) Covered Products already distributed to Downstream releases prior to the Effective Date may continue to be sold through as is.
*Non-Contingent Civil Penalty:
$ 20,000.00
Attorney(s) Fees and Costs:
$ 75,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 95,000.00
Will settlement be submitted to court?
Yes
Contact Name: 
Reuben Yeroushalmi
Contact Organization: 
Yeroushalmi & Yeroushalmi Law Firm
Email Address:
admin@Yeroushalmi.com
Address: 
9100 Wilshire Blvd 240w
City, State, Zip:
Beverly Hills, CA 90212
Phone Number:
(310) 623-1926
Comments: 
Settlement also pertains to AG # 2019-01875, 2019-01629, 2019- 02082, 2019-01648, 2019- 01782, 2019-07162, 2019-01832, 2019-01029, 2019-01508, 2019-01733, 2019-01234, 2018- 01443, and 2018-01534
Corrected Settlement
AG Number:
2019-01868
Settlement PDF: 
Settlement Date:
06/21/2023
Case Name: 
Consumer Advocacy Group, Inc v. Ross Dress for Less, Inc.
Court Name: 
Los Angeles County Superior Court
Court Docket Number: 
20STCV03564
Plaintiff: 
Consumer Advocacy Group, Inc.
Plaintiff Attorney: 
Reuben Yeroushalmi
Defendant: 
Ross Stores, Inc.
Injunctive Relief: 
3.1) After the Effective Date, Ross shall not order any Covered Products for sale into California, with any component that contains the Listed Chemical(s) in excess of 0.1% (1,000 parts per million) by weight. 3.2) Any Covered Products that Ross sells, distributes, or ships into California after the Effective Date that were ordered prior to the Effective Date, must contain a clear and reasonable warning, consistent with 27 CCR section 25600 et seq., unless it contains no more than 0.1% by weight (1,000 ppm) of the Listed Chemical(s). Any warnings provided pursuant to this Section 3.2 shall be affixed to the packaging of, or directly on, or attached to the Covered Products, and be prominently placed with such conspicuousness as compared with other words, statements, designs, or devices as to render it likely to be read and understood by an ordinary individual under customary conditions before purchase or use. The Parties agree that the following warning shall constitute compliance with Proposition 65 with respect to the Listed Chemical in the Covered Products for any Covered Products that Ross sells, distributes or ships into California after the Effective Date that contains the Listed Chemical(s) in excess of 0.1% (1,000 parts per million) by weight: 3.3) For Products containing DEHP: WARNING: This product can expose you to chemicals including Bis(2-ethylhexyl) phthalate (“DEHP”), which is known to the State of California to cause cancer and reproductive toxicity. For more information go to www.P65Warnings.ca.gov. or 3.4 For Products containing DINP: WARNING: This product can expose you to chemicals including Diisononyl Phthalate (“DINP”), which is known to the State of California to cause cancer. For more information go to www.P65Warnings.ca.gov 3.5) Covered Products already distributed to Downstream releases prior to the Effective Date may continue to be sold through as is.
*Non-Contingent Civil Penalty:
$ 20,000.00
Attorney(s) Fees and Costs:
$ 75,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 95,000.00
Will settlement be submitted to court?
Yes
Contact Name: 
Reuben Yeroushalmi
Contact Organization: 
Yeroushalmi & Yeroushalmi Law Firm
Email Address:
admin@Yeroushalmi.com
Address: 
9100 Wilshire Blvd 240w
City, State, Zip:
Beverly Hills, CA 90212
Phone Number:
(310) 623-1926
Comments: 
Settlement also pertains to AG # 2019-01875, 2019-01629, 2019- 02082, 2019-01648, 2019- 01782, 2019-07162, 2019-01832, 2019-01029, 2019-01508, 2019-01733, 2019-01234, 2018-01443, and 2018-01534
Corrected Settlement
AG Number:
2019-01868
Settlement PDF: 
Settlement Date:
04/21/2022
Case Name: 
Consumer Advocacy Group, Inc. v. Ross Stores, Inc., et al.
Court Name: 
Los Angeles County Superior Court
Court Docket Number: 
20STCV03564
Plaintiff: 
Consumer Advocacy Group, Inc.
Plaintiff Attorney: 
Yeroushalmi & Yeroushalmi
Defendant: 
Ross Stores, Inc.
Injunctive Relief: 
After the Effective Date, Ross shall not order any Covered Products for sale into California, with any component that contains the Listed Chemical(s) in excess of 0.1% (1,000 parts per million) by weight. Any Covered Products that Ross sells, distributes, or ships into California after the Effective Date that were ordered prior to the Effective Date, must contain a clear and reasonable warning, consistent with 27 CCR section 25600 et seq., unless it contains no more than 0.1% by weight (1,000 ppm) of the Listed Chemical(s). Any warnings provided pursuant to this Section 3.2 shall be affixed to the packaging of, or directly on, or attached to the Covered Products, and be prominently placed with such conspicuousness as compared with other words, statements, designs, or devices as to render it likely to be read and understood by an ordinary individual under customary conditions before purchase or use.
*Non-Contingent Civil Penalty:
$ 20,000.00
Attorney(s) Fees and Costs:
$ 75,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 95,000.00
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
Fax Number:
(310) 623-1930
Comments: 
This Amended [Proposed] settlement relates to AG Nos.: 2019-01875, 2019-01629, 2019-02082, 2019-01648, 2019-07182, 2019-07162, 2019-01832, 2019-01029, 2019-01508, 2019-01733, 2019-01234, 2018-01443, and 2018-01534
Settlement
AG Number:
2019-01868
Settlement PDF: 
Settlement Date:
08/12/2021
Case Name: 
Consumer Advocacy Group, Inc. v. Ross Stores, Inc., et al.
Court Name: 
Los Angeles County Superior Court
Court Docket Number: 
20STCV03564
Plaintiff: 
Consumer Advocacy Group, Inc.
Plaintiff Attorney: 
Reuben Yeroushalmi
Defendant: 
Ross Stores, Inc.
Injunctive Relief: 
After the Effective Date, Ross shall not order any Covered Products for sale into California, with any component that contains the Listed Chemical(s) in excess of 0.1% (1,000 parts per million) by weight. Any Covered Products that Ross sells, distributes, or ships into California after the Effective Date that was ordered 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) of the Listed Chemical(s). Any warnings provided pursuant to this Section 3.2 shall be affixed to the packaging of, or directly on, or attached to the Covered Products, and be prominently placed with such conspicuousness as compared with other words, statements, designs, or devices as to render it likely to be read and understood by an ordinary individual under customary conditions before purchase or use.
*Non-Contingent Civil Penalty:
$ 20,000.00
Attorney(s) Fees and Costs:
$ 75,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 95,000.00
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
Fax Number:
(310) 623-1930
Comments: 
This Settlement also relates to AG Nos.: 2019-01875, 2019-01629, 2019-02082, 2019-01648, 2019-01782, 2019-07162, 2019-01832, 2019-01029, 2019-01508, 2019-01733, 2019-01234, 2018-01443, and 2018-01534,
Judgment
AG Number:
2019-01868
Judgment PDF: 
Judgment Date:
07/06/2023
Settlement reported to AG: 
Wed, 06/21/2023
Case Name: 
Consumer Advocacy Group, Inc v. Ross Dress for Less, Inc.
Court Name: 
Los Angeles County Superior Court
Court Docket Number: 
20STCV03564
Plaintiff: 
Consumer Advocacy Group, Inc.
Plaintiff Attorney: 
Reuben Yeroushalmi
Defendant: 
Ross Stores, Inc.
Injunctive Relief: 
3.1) After the Effective Date, Ross shall not order any Covered Products for sale into California, with any component that contains the Listed Chemical(s) in excess of 0.1% (1,000 parts per million) by weight. 3.2) Any Covered Products that Ross sells, distributes, or ships into California after the Effective Date that were ordered prior to the Effective Date, must contain a clear and reasonable warning, consistent with 27 CCR section 25600 et seq., unless it contains no more than 0.1% by weight (1,000 ppm) of the Listed Chemical(s). Any warnings provided pursuant to this Section 3.2 shall be affixed to the packaging of, or directly on, or attached to the Covered Products, and be prominently placed with such conspicuousness as compared with other words, statements, designs, or devices as to render it likely to be read and understood by an ordinary individual under customary conditions before purchase or use. The Parties agree that the following warning shall constitute compliance with Proposition 65 with respect to the Listed Chemical in the Covered Products for any Covered Products that Ross sells, distributes or ships into California after the Effective Date that contains the Listed Chemical(s) in excess of 0.1% (1,000 parts per million) by weight: 3.3) For Products containing DEHP: WARNING: This product can expose you to chemicals including Bis(2-ethylhexyl) phthalate (“DEHP”), which is known to the State of California to cause cancer and birth defects or other reproductive harm. For more information go to www.P65Warnings.ca.gov. or 3.4 For Products containing DINP: WARNING: This product can expose you to chemicals including Diisononyl Phthalate (“DINP”), which is known to the State of California to cause cancer. For more information go to www.P65Warnings.ca.gov 3.5) Covered Products already distributed to Downstream releases prior to the Effective Date may continue to be sold through as is.
*Non-Contingent Civil Penalty:
$ 20,000.00
Attorney(s) Fees and Costs:
$ 75,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 95,000.00
Is Judgment Pursuant to Settlement?
Yes
Contact Name: 
Reuben Yeroushalmi
Contact Organization: 
Yeroushalmi & Yeroushalmi Law Firm
Email Address:
admin@Yeroushalmi.com
Address: 
9100 Wilshire Blvd 240w
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.