60 Day Notice 2024-00781

AG Number: 
2024-00781
Notice PDF: 
Date Filed: 
02/26/2024
Noticing Party: 
Chemical Toxin Working Group Inc. dba Healthy Living Foundation
Plaintiff Attorney: 
Poulsen Law P.C.
Alleged Violators: 
Rappahannock River Oysters, LLC
Rapp Bar DTLA LLC
Chemicals: 
Cadmium
Lead and lead compounds
Source: 
Oysters

60-Day Notice Document

Settlement
AG Number:
2024-00781
Settlement PDF: 
Settlement Date:
02/28/2025
Case Name: 
CHEMICAL TOXIN WORKING GROUP INC. v. RAPPAHANNOCK
Court Name: 
Los Angeles County Superior Court
Court Docket Number: 
23STCV19296
Plaintiff: 
Chemical Toxin Working Group Inc. dba Healthy Living Foundation
Plaintiff Attorney: 
Poulsen Law P.C.
Defendant: 
RAPPAHANNOCK RIVER OYSTERS, LLC
Rapp Bar DTLA LLC
Injunctive Relief: 
Any Covered Products that a Defendant distributes into the State of California after the Compliance Date, shall either (1) comply with the warning requirements of Section 3.2 or (2) meet the reformation requirements under Section 3.3.
*Non-Contingent Civil Penalty:
$ 40,700.00
Attorney(s) Fees and Costs:
$ 118,800.00
Payment in Lieu of Penalty:
$ 30,500.00  ( (Plaintiff will use thispayment as follows: Eighty percent (80%) for fees of investigation, purchasing and testing for Proposition 65 listed chemicals in various products, and for expert fees for evaluating exposures through various mediums, including but not limited to consumer product, occupational, and environmental exposures to Proposition 65 listed chemicals, and the cost of hiring consulting and retaining experts who assist with the extensive scientific analysis necessary for those files in litigation and to offset the costs of future litigation enforcing Proposition 65 but excluding attorney fees; for publishing periodicals and other medias regarding public awareness about the issue of environmental pollution and presence of Proposition 65 chemicals in the environment and consumer products; donations and supplies, including but not limited to, water filters and air filters for public schools and communities, to regions impoverished by industrial pollution. And twenty percent (20%) for administrative costs incurred during investigation and litigation to reduce the public’s exposure to Proposition 65 listed chemicals by notifying those persons and/or entities believed to be responsible for such exposures and attempting to persuade those persons and/or entities to reformulate their products or the source of exposure to completely eliminate or lower the level of Proposition 65 listed chemicals including but not limited to costs of documentation and tracking of products) )
Total Payments:
$ 190,000.00
Will settlement be submitted to court?
Yes
Contact Name: 
Aida Poulsen
Contact Organization: 
Poulsen Law P.C.
Email Address:
contact@poulsenlaw.org
Address: 
282 11TH AVE SUITE 2612
City, State, Zip:
NEW YORK, NY 100011278
Phone Number:
(646) 766-5999


* 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.