60 Day Notice 2018-00452

AG Number: 
2018-00452
Notice PDF: 
Date Filed: 
03/21/2018
Noticing Party: 
Tamar Kaloustian
Plaintiff Attorney: 
Vache Thomassian, Esq.
Alleged Violators: 
HERBAL SECRETS
Chemicals: 
Lead
Source: 
HERBAL SECRETS – ORGANIC WHOLE PSYLLIUM HUSK

60-Day Notice Document

Settlement
AG Number:
2018-00452
Settlement PDF: 
Settlement Date:
07/02/2019
Case Name: 
TAMAR KALOUSTIAN v. HERBAL SECRETS
Court Name: 
Los Angeles County Superior Court
Court Docket Number: 
OUT OF COURT SETTLEMENT
Plaintiff: 
TAMAR KALOUSTIAN
Plaintiff Attorney: 
Vache Thomassian
Defendant: 
HERBAL SECRETS
Injunctive Relief: 
Herbal Secrets agrees, promises, and represents that, as of sixty days after the Effective Date, to the extent it ships or sells into the State of California any Covered Products in existing inventory as of that date, it will provide warnings on such Covered Products that comply with Proposition 65. The warnings shall be provided in such a conspicuously and prominent manner that will assure the message is made available and likely to be read, seen, or heard by the consumer prior to or at the time of the sale or purchase. The Parties agree that product labeling stating that “WARNING: Consuming this product can expose you to a chemical known to the State of California to cause cancer or reproductive harm” shall constitute compliance with Proposition 65 with respect to the Listed Chemical in the Covered Products.
*Non-Contingent Civil Penalty:
$ 1,000.00
Attorney(s) Fees and Costs:
$ 9,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 10,000.00
Will settlement be submitted to court?
Will settlement be submitted to court?: 
No
Contact Name: 
Vache Thomassian
Contact Organization: 
KJT Law Group, LLP
Email Address:
vache@kjtlawgroup.com
Address: 
230 N. Maryland Ave. Suite 306
City, State, Zip:
Glendale, CA 91206
Phone Number:
(818) 507-8525
Fax Number:
(818) 507-8588


* 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.