60 Day Notice 2024-00952

AG Number: 
2024-00952
Notice PDF: 
Date Filed: 
03/08/2024
Noticing Party: 
Keep America Safe and Beautiful
Plaintiff Attorney: 
Stephanie Sy
Alleged Violators: 
Instacart.com
Quinoa Corporation
Chemicals: 
Lead
Source: 
Pamela's Whenever Bars Oat Raisin

60-Day Notice Document

Corrected Settlement
AG Number:
2024-00952
Settlement PDF: 
Settlement Date:
10/16/2024
Case Name: 
Keep America Safe and Beautiful vs. Quinoa Corporation
Court Name: 
Private
Court Docket Number: 
none
Plaintiff: 
Keep America Safe and Beautiful
Plaintiff Attorney: 
stephanie sy
Defendant: 
Quinoa Corporation
Injunctive Relief: 
Warning
*Non-Contingent Civil Penalty:
$ 500.00
Attorney(s) Fees and Costs:
$ 14,500.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 15,000.00
Will settlement be submitted to court?
Yes
Contact Name: 
Stephanie Sy
Contact Organization: 
Law Offices of Stephanie Sy
Address: 
11622 El Camino Real, Suite 100, Suite 100
City, State, Zip:
San Diego, CA 92130
Phone Number:
(858) 610-0598
Comments: 
AG's office corrected the initial typo ($145,000 vs $14,500), but we noticed court information was incorrect. This is a private settlement. Just correcting the info
Corrected Settlement
AG Number:
2024-00952
Settlement PDF: 
Settlement Date:
10/16/2024
Case Name: 
Keep America Safe and Beautiful v. Quinoa
Court Name: 
Orange County Superior Court
Court Docket Number: 
N/A
Plaintiff: 
Keep America Safe and Beautiful
Plaintiff Attorney: 
Stephanie Sy
Defendant: 
Quinoa
Injunctive Relief: 
Commencing one hundred eighty (180) days after the Execution Date, Quinoa shall not sell, offer for sale, ship for sale or otherwise distribute or allow to be distributed in California any Covered Products, unless the sales and distribution of the Covered Products are in full compliance with California Code of Regulations, Title 27, Article 6, Clear and Reasonable Warning Requirements § 25601-25603 (see also: “www.P65Warnings.ca.gov.”). Covered Products that were manufactured, packed, or labeled prior to the Execution Date and up to 180 days after the Execution Date shall be permitted to be sold as previously manufactured, packed or labeled. As used in this Settlement Agreement, the term "distributing in California" shall mean to directly ship a Covered Product into California for sale in California or to sell a Covered Product to a distributor that Quinoa knows or has reason to know will sell the Covered Product in California. Clear and Reasonable Warnings. If Quinoa is required to provide a warning pursuant to Section 2.1, the language of that warning shall be as follows: For purposes of this Settlement Agreement, the term "label" means a display of written, printed or graphic material that is printed on or affixed to a Covered Product or its immediate container or wrapper. If KASB alleges that any Covered Product fails to adhere to this Agreement, then KASB shall inform Quinoa in a reasonably prompt manner of its test results, including information sufficient to permit Quinoa to identify the Covered Products at issue and investigate. The Parties shall first attempt to resolve the matter prior to KASB taking any further legal action including the filing of a Notice of Violation.
*Non-Contingent Civil Penalty:
$ 500.00
Attorney(s) Fees and Costs:
$ 14,500.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 15,000.00
Will settlement be submitted to court?
Yes
Contact Name: 
Stephanie Sy
Contact Organization: 
Law Offices of Stephanie Sy
Address: 
11622 EL CAMINO REAL
City, State, Zip:
San Diego, CA 92130
Phone Number:
(858) 746 9554
Settlement
AG Number:
2024-00952
Settlement PDF: 
Settlement Date:
09/30/2024
Case Name: 
Keep America Safe and Beautiful v. Quinoa
Court Name: 
Private Settlement
Court Docket Number: 
N/A
Plaintiff: 
Keep America Safe and Beautiful
Plaintiff Attorney: 
Stephanie Sy
Defendant: 
Quinoa
Injunctive Relief: 
WARNINGS: Commencing one hundred eighty (180) days after the Execution Date, Quinoa shall not sell, offer for sale, ship for sale or otherwise distribute or allow to be distributed in California any Covered Products, unless the sales and distribution of the Covered Products are in full compliance with California Code of Regulations, Title 27, Article 6, Clear and Reasonable Warning Requirements § 25601-25603 (see also: “www.P65Warnings.ca.gov.”). Covered Products that were manufactured, packed, or labeled prior to the Execution Date and up to 180 days after the Execution Date shall be permitted to be sold as previously manufactured, packed or labeled. As used in this Settlement Agreement, the term "distributing in California" shall mean to directly ship a Covered Product into California for sale in California or to sell a Covered Product to a distributor that Quinoa knows or has reason to know will sell the Covered Product in California.
*Non-Contingent Civil Penalty:
$ 500.00
Attorney(s) Fees and Costs:
$ 145,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 145,500.00
Will settlement be submitted to court?
Yes
Contact Name: 
Stephanie Sy
Contact Organization: 
Law Offices of Stephanie Sy
Address: 
11622 EL CAMINO REAL
City, State, Zip:
San Diego, CA 92130
Phone Number:
(858) 746 9554


* 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.