60 Day Notice 2022-00113

AG Number: 
2022-00113
Notice PDF: 
Date Filed: 
01/20/2022
Noticing Party: 
Environmental Research Center, Inc.
Plaintiff Attorney: 
Environmental Research Center
Alleged Violators: 
Honeybrains LLC
Honeybrains 22 LLC
Honeybrains 55 LLC
Honeybrains 5th Ave LLC
Honeybrains Lafayette LLC
Honeybrains Biotech LLC
Chemicals: 
Lead and lead compounds
Source: 
Dietary supplement

60-Day Notice Document

Settlement
AG Number:
2022-00113
Settlement PDF: 
Settlement Date:
02/16/2022
Case Name: 
Environmental Research Center, Inc. v. Honeybrains LLC
Court Name: 
Out of Court Settlement
Court Docket Number: 
N/A
Plaintiff: 
Environmental Research Center, Inc.
Plaintiff Attorney: 
Charles Poss
Defendant: 
Honeybrains LLC
Honeybrains 22, LLC
Honeybrains 55 LLC
Honeybrains 5th Ave LLC
Honeybrains Lafayette LLC
Honeybrains Biotech LLC
Injunctive Relief: 
SAR sect. 3.1 - Beginning on the Effective Date, Honeybrains shall be permanently enjoined from manufacturing for sale in the State of California, “Distributing into the State of California,” or directly selling in the State of California, any Covered Product which exposes a person to a “Daily Lead Exposure Level” of more than 0.5 micrograms of lead per day unless it meets the warning requirements under Section 3.2.
*Non-Contingent Civil Penalty:
$ 500.00
Attorney(s) Fees and Costs:
$ 4,500.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 5,000.00
Will settlement be submitted to court?
No
Contact Name: 
Charles Poss
Contact Organization: 
Environmental Research Center, Inc.
Email Address:
charles.poss@erc501c3.org
Address: 
3111 Camino Del Rio North, 400
City, State, Zip:
San Diego, CA 92108
Phone Number:
(619) 500-3090


* 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.