bun 21 ystal ltd. - Prop 65 News Documents

Transcription

PROP65
© Prop 65 News. All Rights Reserved.
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WILLIAM S. LERACH, ESQ., No. 68581
MILBERG WEISS BERSHAD
SPECTHRIE & LERACH
225 Broadway, Suite 2000
San Diego, CA 92101
(619) 2 3 1 - 1 0 5 8
News-18557
ENDORSED
FILED
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Sin FrenclscoCount),SUeD#OrCourt
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/~ALAN M. CAPLAN, ESQ., NO. 49315
5 ~ B U S H N E L L , CAPLAN & FIELDING
) 9 0 1 Market Street, Suite 230
6 ~ S a n Francisco, CA 94103
I(415)
777-5010
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Attorneys for Plaintiff
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JU; 2 ..139,]
ALAN CARLCJON, C;ork
BY: __ GARTH 8AYER$ ,
Depu:yClerk--
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
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IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
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JANET C. MANGINI, on behalf of
the general public,
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(Consolldated Matters )
Nos. 932724, 9 3 1 8 8 4 , 9 3 8 1 7 3
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Plaintiff,
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v.
ACTION INDUSTRIES, INC.; ACTION
INTERNATIONAL, LTD.; AEGIS
ENTERPRISE, INC. d/b/a OFNAH
TRADING CO.; ALEXANDER INDUSTRIES
CORP.; ALEXANDER INDUSTRIES LTD.;
AMERICAN COMMERCIAL INCORPORATED;
AMERICAN CUT CRYSTAL CORP.; ANCHOR
HOCKING GLASS CORP. (a Member of
the Newel1 Group); ANNA HUTTE GmbH
KRISTALLGLASFABRIK; AVON PRODUCTS,
INC.; BACCARAT, INC.; BADASH, JACK
INC.; BEYER & CO. GmbH
KRISTAUGLASFABRIKEN; BLOCK CHINA
CORPORATION; BORMIOLI ROCCO GLASS
CO., ~ ;
BUFFALO CHINA, INC.;
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C. A, L;i~:~I!~::SpA; CARTIER,
INCORP~PJ%TED," CAVAN CRYSTAL
GROUP LTD.; CAVAN IRISH CRYSTAL
LTD; CESKA, INC.; CFC DAUM INC.;
CFC DAUM ITALIA SpA; CFC DAUM PTL
LTD; CLAUS JOSEPH RIEDEL, TIROLER
GLASSHUTTE Ges.M.G.H.; COLLE SRL;
COLONY (a Division of Lancaster
Colony Corp.); COMPAGNIE des
CRISTALLERIES de BACCARAT;
COMPAGNIE des CRISTALLERIES ~ e
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BUN 21 YSTAL LTD.,
MANGINI
CONSENT
CONSENT
JUDGMENT
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JUDGMENT
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S A I N T LOUIS; C O M P A G N I E F R A N C A I S E
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du C R I S T A L - D A U M ; C R I S A CORPORATION; )
)
2 C R I S A L - C R I S T A I S DE ALCOBACA, S.A.;
C R I S T A L L E R I E A R T I S T I C A LA P I A N A
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3 SpA; C R I S T A L L E R I E S DE LORRAINE;
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C R Y S T A L C L E A R INDUSTRIES; C R Y S T A L
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DESIGNS OF TIPPERARY, LTD.;
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C R Y S T A L G I F T W A R E INC.; D A N S K
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I N T E R N A T I O N A L DESIGNS, LTD.;
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D A R T I N G T O N C R Y S T A L LIMITED;
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D A U M BOUTIQUE; DESIGN GUILD;
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D E V O N C R Y S T A L LIMITED; D I N N E R W A R E
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PLUS, (CA) INC.; D. J. TABLEWARE,
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INC.; D O N E G A L C R Y S T A L USA INC.;
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DUBLIN C R Y S T A L GLASS CO. (IRELAND)
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LIMITED; THE E D I N B U R G H C R Y S T A L
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9 GLASS C O M P A N Y LTD.; ESSEX
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M A R K E T I N G INC.; EUPORT, INC.;
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10 5TH (FIFTH AVENUE); F.X. N A C H T M A N N
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B L E I K R I S T A L L W E R K E GmbH; G A L L O
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DESIGN GmbH; G A L W A Y CRYSTAL US,
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INC.; G L A S S E X P O R T CO., LTD.;
)
12 G L A S W E R K E WARMENSTEINACH; G O D I N G E R
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I N T E R N A T I O N A L INC.; G O D I N G E R
)
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S I L V E R ART, LTD.; GOEBEL ART GmbH;
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G O E B E L U N I T E D STATES (a Division
)
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of Goebel A r t GmbH); GOLD LEAF
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T R A D I N G INC.; GORHAM, INC.;
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H O F B A U E R BLEIKRISTALL; HOYA
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C O R P O R A T I O N - C R Y S T A L DIVISION;
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H O Y A C R Y S T A L USA; IMPERIAL
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C R Y S T A L S & C H I N A CO., INC.; IMPORT
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17 A S S O C I A T E S (a Division of Imtrac
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Industries, Inc.); IMPORT
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18 A S S O C I A T E S , INC.; IMPORTS BY
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ASTRAL, INC.; IMTRAC INDUSTRIES,
)
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INC.; INN C R Y S T A L GLASS GmbH;
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INN C R Y S T A L V E R T R I E B S Q E S & CO.
)
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GmbH; J A C Q U E S JUGEAT, INC.;
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J O N A L C R Y S T A L LTD.; KAGAMI C R Y S T A L
)
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CO., LTD. I K&M MOSTNY, INC.;
)
K E N W O Q D S I L V E R COMPANY, INC.:
)
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KILLY~S
CRYSTAL, LTD.; KOSTA
)
BODA ~ A , LTD.; K R I S T A L L G L A S F A B R I K
)
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SPIEG~U
GmbH; LALIQUE; LALIQUE
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S.A.; L A N C A S T E R COLONY CORPORATION; )
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LENOX, INCORPORATED; M. L E U P O L D
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GmbH; L I B B E Y GLASS, INC.;
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L O U I S E G L A S S COMPANY, INC.;
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M A N U F A C T U R E DE CRISTAUX DU VAL
)
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S A I N T L A M B E R T SA/NU; M A X W E L L
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CRYSTAL, INC.; MIKASA, INC.; MILLER )
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IMPORT CORP.; M I L L E R ROGASKA,
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CRYSTAL; M I L L E R - R O G A S K A INC.;
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MOSTNY, INC.; NACHTMANN u.S'A.,
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MANGINI
CONSENT JUDGMENT
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News-18559
INC.; N A N C Y C A L H O U N INC.; N E U W I R T H
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CO. INC.; N E W E L L COMPANY; N O R I T A K E
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CO., INC. (USA); N O R I T A K E CO.,
)
L I M I T E D (JAPAN); ONEIDA D I S T R I B U T I O N )
SERVICES,'INC.; O N E I D A F A C T O R Y
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STORES; O N E I D A F O O D S E R V I C E
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DIVISION; O N E I D A INTERNATIONAL,
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INC.; O N E I D A LTD.; ONEIDA S A V I N G S
)
PLAN: O N E I D A S I L V E R S M I T H S DIVISION; )
ORREFORS, INC.; PASABAHCE; PASABAHCE)
T I C A R E T L I M I T E D SIRKETI;
)
P I T M A N - D R E I T Z E R ; POLO R A L P H L A U R E N
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C O R P O R A T I O N ; P R I N C E S S HOUSE, INC.;
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RCR, INC.; R O G A S K A CRYSTAL BY
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M I L L E R R O G A S K A ; R O S E N T H A L NORTH
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AMERICA; R O S E N T H A L USA LIMITED;
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R O Y A L BRIERLEY; R O Y A L B R I E R L E Y
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C R Y S T A L INC.; R O Y A L B R I E R L E Y
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C R I S T A L LTD.; R O Y A L CRYSTAL ROCK,
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INC.; R O Y A L D O U L T O N USA INC.: R O Y A L )
MONARCH, LTD.; R U S S I A N A M E R I C A N
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C O M M E R C I A L CORP.; SAINT LOUIS
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C R I S T A L DE FRANCE, INC.; SANT'
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A N D R E A S.r.1.; SASAKI GLASS CO.
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LTD.; SASAKI, INC.; SAXONY, INC.;
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SCHOTT CORPORATION; SCHOTT-ZWIESEL
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GLASS, INC.;
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S C H O T T - Z W I E S E L - G L A S W E R K E AG;
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S C U L P T U R E D C R Y S T A L (IRELAND) LTD.;
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S O C I E T E N O U V E L L E DES C R I S T A L L E R I E S
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DE LORRAINE; S T E K L A R N A BORIS KIDRIC )
R O G A S K A S L A T I N A SLOVENIJA;
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ST. G E O R G E C R Y S T A L LTD.; S T U A R T &
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SONS LIMITED; STYLESETTERS:
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S U L L I V A N INC.; S V E N D J E N S E N OF
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DENMARK, INC.; T A B L E W A R E & GIFTS,
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INC.; T A M L O N A N D COMPANY; T A M C O N
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INC.; T I F F A N Y A N D COMPANY; THE
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LIGHTERS; THE LS COLLECTION;
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T O S C A N Y C L A S S I C S LTD.; T U D O R
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C R Y S T A L LIMITED; TYRONE C R Y S T A L
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LIMITED; ULLMANNGLASS: U.S.T.I.,
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INCOR~TED;
VAL SAINT L A M B E R T
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USA, ~: 2~ , ~ " VERWALTUNGS. SmbH ;
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VILL~&
B O C H AG; VILLEROY & BOCH )
S.a.r.~;.; V I L L E R O Y & BOCH T A B L E W A R E )
LTD.; V I T R O C R I S A KRISTAL S.A. DE
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C.V.; W A T E R F O R D W E D G W O O D P.L.C.
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(and its s u b s i d i a r i e s and
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affiliates); WMF/HUTSCHENREUTHER
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P A R T N E R S H I P USA (d/b/a WMF
)
H U T S C H E N R E U T H E R USA),
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Defendants.
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MANGINI
CONSENT JUDGMENT
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PROP65
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STIIW/LATION FOR ENTRY OF J U D G M E N T A N D O R D E R
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I. INTRODUCTION
1.
On May 30, 1991, Plaintlff Janet C. Manglnl
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(hereinafter,
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Injunctive Rellef (No. 932724, hereinafter, the "Manglni II
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Complaint-)
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BACCARAT,
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MARTEL; W A T E R F O R D WEDGEWOOD;
WATERFORD W E D G E W O O D RETAIL,
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ORREFORS; M A C Y ' S CALIFORNIA,
INC.; SHREVE & CO.; GUMPS; and
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"Plaintiff") filed a Complaint for Damages and
in this court (hereinafter, "Court"), naming
INC. ; LALIQUE; GALWAY IRISH CRYSTAL U.S.A., INC. ; JJF
DOES 1 through 200 as defendants
2.
INC. ;
(hereinafter "Defendants,,).
Plalntiff previously filed, and subsequently amended,
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two addltlonal complaints in this Court (respectively,
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Nos. 931884 and 938173, hereinafter, the "Manginl I and
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Mangini III Amended Complaints-) against some or all of t h e
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Defendants, as well as against HOYA CRYSTAL, KOSTA BODA, and
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SAKS & COMPANY.
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3.
Prior to filing this Consent Judgment, Plaintlff
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amended the Mangini II Complaint to include addltlonal named
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defendants and legal theories.
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entered an order allowing the amended Mangini II Complaint to
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be consolldated with the Mangini I and III Amended Complaints
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for thd~purposes of this Consent Judgment.
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Mangln~ ~ II Complalnt and the Mangini I and III Amended
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Complaints are hereinafter referred to as the "Consolidated
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Complaints,, and the defendants named in the Consolidated
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Complaints are hereinafter referred to as the "Settling
Upon further motion, this court
(The amended
4.
PROP65
News-18561
The Settling Defendants are deemed to have appeared in
this action and are beneficiaries of this Consent Judgment.
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5.
Those Defendants named in the Mangini II Complaint
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and/or in the Mangini I and III Amended Complaints, but not in
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the Consolidated Complaints are not appearing in this action,
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but nevertheless may be beneficiaries of the consent Judgment
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pursuant to Section V herein.
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6.
The Consolidated Complaints are based on allegations
that the Settling Defendants violated certain provisions of
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Cal. Business and Professions Code $$ 17200 et seq.
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(hereinafter,
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Water and Toxic Enforcement Act of 1986, Cal. Health & Safety
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Code $$ 25249.6 et seq. (hereinafter, "Proposition 65"), by:
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knowingly exposing individuals in the State of Calif0rnia to~
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lead through the manufacture, distribution, and sale of crystal
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products containing lead used with food or beverages
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(hereinafter, "Leaded Crystal Products,,), including, among
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others, certain decanters, glasses, and other serveware,
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without first providing clear and reasonable warnings to
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persons who could potentlally be exposed to lead through the
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use of such products.
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7~Since
"Unfair Competition Act") and the Safe Drinking
the filing of the Mangini I Complaint, the
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SettllngDefendants have implemented a system which is intended
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to provide potential purchasers of Leaded Crystal Products with
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warnings pursuant to Proposition 55.
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of the warnings were discussed by representatives of the
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Settling Defendants with the Attorney General's Office prior to
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MANGINI CONSENT JUDGMENT
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The language and format
PROP65
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their implementatlon.
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8.
For purposes of this Consent Judgment only, Plaintiff
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and the Settllng Defendants stipulate that this Court has
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Jurisdiction
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the Consolldated
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Settling Defendants as to the acts alleged in the Consolidated
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Complaints,
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San Francisco,
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this Consent Judgment as a full and final resolution of the
over the allegations
of vlolatlons
Complaints and personal
contained
in
jurisdiction over the
that venue ks proper in the City and County of
and that this Court has jurisdiction
to enter
]0
allegations
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and all causes of action that may have been or were asserted
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therein.
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News-18562
9.
contained in the Consolidated
Complaints and any
Plalntiff and the Settling Defendants
enter into this
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Consent Judgment to resolve the disputed cl~ims of the
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Consolidated
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alleged therein or otherwise impllcated by exposures to lead in
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Leaded Crystal Products,
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insure that the objectives of Proposition
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Competition Act are expedltlously carried out in furtherance of
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the public interest.
Complaints and all matters raised by the facts
to avoid prolonged
lltigation,
and to
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10.
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not ~ t
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Competition<Act,
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apply to the facts alleged in the Consolidated
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Nothing in this Consent Judgment shall be construed as an
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admission by the Settling Defendants of any fact,
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or violation of law, nor shall compliance with this Consent
By execution of this Order, the Settling Defendants do
any vlolations of Proposition
65, the Unfair
or other statutes or causes of action that may
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Complaints.
issue of law
PROP65
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Judgment constitute or be construed as an admission by the
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Settling Defendants
law.
of a n y fact,
issue of law or violation of
Nath-inq in this Consent J u d g m e n t shall prejudice,
waive
4
or impair any right, remedy or defense the Settling Defendants
5
may have in any other or future legal proceeding.
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this Paragraph shall not diminish or otherwise affect the
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obligations,
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Defendants
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11.
responsibilities
and duties of the Settling
under this Consent Judgment.
The agreement reflected
in this Consent Judgment has
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been reviewed and approved of by the California
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General
Attorney
in a letter dated April 2, 1993.
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However,
II. WARNING PROGRAM
12.
Clear and reasonable warning that use of Leaded
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Crystal Products exposes persons to lead, a c h e m i c a l known to
15
the State of California
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reproductive
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in the m a n n e r provided in Paragraphs
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Upon receiving the written agreement of the Attorney General's
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Office,
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alternative
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warnings shall be required pursuant to this Paragraph where a
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Settllng Defendant has provided the Attorney General's Office
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with data demonstrating
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of lead from a Leaded Crystal Product at least sixty (60) days
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in a d v a n c e of making such product available
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State of California.
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13.
harm,
to cause birth defects or other
shall be provided by the Settling Defendants
a Settling Defendant may provide warnings
m a n n e r to the r e q u i r e m e n t s
in an
of this Paragraph.
that there is no dectectable
CONSENT
JUDGMENT
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No
leaching
fur sale in the
By no later than June 30, 1993, each Settling
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MANGINI
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PROP65
News-18564
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Defendant,
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central purchasing
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stores with whom it transacts business for sale of Leaded
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Crystal Products
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sign contained
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printed on 65-pound cover stock and 2) a letter explaining the
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warning program and providing posting instructions.
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Warning Sign shall be 8-1/2,, by 11" in size and shall have the
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exact content,
or an entity acting on its behalf,
office for a11 distributors
in California:
shall mail to the
and retail
1) at least five copies of the
in Exhibit A (hereinafter,
the "Warning Sign"),
form, and print style as Exhibit A.
The
The letter
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and warning instructions referred to in this Paragraph shall
1]
contain the text shown in Exhibit B, and shall contain no
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further information or statements
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approval of the California Attorney General's Office.
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14.
without the advance written
Warning Signs shall be placed in each California
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retail establishment
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Leaded Crystal Products are sold by no later than July 31,
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1993.
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products that do not require a warning,
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post the Warning Sign.
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obscured,
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rendering them likely to be read and understood by an ordinary
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individual
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Specifically,
in which any of the Settling Defendants,
Where a retail establishment
24
sells only leaded crystal
it is not required to
Warning Signs shall not be covered or
and shall be placed and displayed
in a manner
under customary conditions of purchase.
a.
such signs shall be placed as follows:
Department stores or other stores with separate
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check-out
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Crystal Products
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section,
for tableware department:
For a store selling Leaded
in a physically separate department or
which contains cash registers within such department
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,
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IIIII
II
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PROP65
News-18565
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or section that are used primarily to purchase
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that d e p a r t m e n t or section,
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register in that section or department, and at a minimum of two
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additional
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displayed
items sold in
signs shall be placed at each cash
locations where Leaded Crystal Products are
within the section or department.
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b.
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tableware department:
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Products and has more than 7,500 square feet of floor space and
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that uses one or more check-out stands for all merchandise
Large stores without a separate check-out for
any store that sells Leaded Crystal
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purchased at the store, a single sign shall be posted at each
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location where Leaded Crystal Products are displayed,
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many addltional signs as are necessary to assure that any
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potential purchaser of tableware would be reasonably likely to
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see a Warning Sign. •
plus as
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c.
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tableware department:
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Products and has 7,500 square feet or less of total floor
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space,
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merchandise
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manner provided
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Small stores without a separate check-out for
any store that sells Leaded Crystal
and uses one or more check-out stands for all
15.
purchased at the store, shall post signs in the
in (a) or (b) above.
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Defendant,
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central purchasing
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has reason to know sells such a Settling Defendant's
Leaded
25
Crystal Products
1) a copy
26
of the Warning Sign and 2) a letter explaining
27
program and providing
shall mail to the
office for each company which it knows or
to residents of California by mail:
instructions
the warning
for d i s t r i b u t i o n
of the
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PROP65
warnings
to Callfornia consumers.
News-18566
The letter and instructions
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referred to in this Paragraph shall contain the text shown in
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Exhibit C and shall contain no further information or
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statements
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Callfornia Attorney General's Office.
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16.
without the advance written approval of the
Where a Settling Defendant's Leaded Crystal Products
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are available
8
of California,
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by no later than July 31, 1993 by including a warning,
for sale by mail order to residents
of the State
clear and reasonable warning shall b e p r o v i d e d
either
J0
in the mail order catalog or brochure or with the Leaded
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Crystal Product when it is shipped to California
J2
follows:
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a.
Mall Order Catalog or Brochure.
customers as
The following
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warning message shall be stated within the catalog or brochure,
15
on the inside front cover,
16
or on the same page as the price,
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"Prop 65 WARNING:
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in this catalog or brochure will expose you to lead, a chemical
19
known to the State of California to cause birth defects or
20
other reproductive
2!
the catalog or brochure require a warning,
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be used as an alternative to the preceding warning message:
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"Prop 65 WARNING:
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crystal tablewar e for sale in this catalog or brochure will
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expose you to lead, a chemical known to the State of California
26
to cause birth defects or other reproductive
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Listing of Brand Names and Exceptions].,,
on the same page as any order form,
in at least 12 point type:
Use of the leaded crystal tableware for sale
harm."
If not all of the items for sale in
the following shall
Use of the following brands of leaded
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10
harm:
[Insert
PROP65
b.
Package
Insert or Label.
Alternatlvely,
warning may be provided with the Leaded Crystal
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they are Shipped,
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measuring
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a pressure-sensitive
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business-card
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printing
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identifying
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size as the description
Products when
at least 4" by 6" in a shipping carton,
(b) affixing
label measuring at least standard
size on the face of the shipping
carton,
the warning on the packing slip or customer
the Leaded Crystal
or (c)
invoice
Product in lettering of the same
of the Leaded Crystal
warning shall read as follows:
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product will expose you to lead, a chemical
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of California
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harm.
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days of receipt,
15.
each brand of leaded crystal
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warning
Product.
"Prop 65 WARNING:
The
Use of this
known to the State
to cause birth defects or other reproductive
You may return this product for a full refund within
if you wish.
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You may also obtain a list of
tableware
for which the same
is given."
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Defendant,
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central purchasing
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restaurant
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transacts
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Products
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sign contained
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and 2) a letter explaining
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posting
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paragraph
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exact content,
office for all restaurant
shall mail to the
suppliers or each
or other food service establishment
business
for the commercial
in California:
with whom it
use of Leaded Crystal
1) at least two copies
of the warning
in Exhibit D, printed on 65-pound
instructions.
cover stock
the warning program and providing
The warning sign referred
to in this
shall be 8-1/2" by 11', in size and shall have the
form, and print style as Exhibit
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MANGINI
a
by (a) inserting a card or slip of paper
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News-18567
CONSENT JUDGMENT
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D.
The letter
PROP65
News-18568
1
and instructions
2
the text shown in Exhibit E and shall contain no further
3
information
4
of the California Attorney General's Office.
5
18.
referred to in this Paragraph shall contain
or statements without the advance written approval
Restaurants,
hotels,
and other food service
6
establishments
l
warning,
8
Products are used for service of food consumed by their
9
customers,
in Californla shall provide clear and reasonable
whenever a Settling Defendant's
Leaded Crystal
by posting an 8-1/2" by 11" sign with the exact
lO
content,
ll
July 31, 1993.
12
cover stock.
13
19.
form, and print style as Exhibit D by no later than
The sign shall be printed on at least 65-pound
A Settling Defendant that has complied with the terms
14
of Paragraphs
15
violated
16
distributor,
17
restaurant,
or any other person required to provide
18
Proposition
65 warnings for Leaded Crystal Products fails to
19
provide such warnings.
20
21
13, 15, and 17 above shall not be found to have
this Consent Judgment where a retail store,
mail order supplier,
restaurant supplier,
III. SETTLEMENT CONSIDERATION,
20.
FEES, AND COSTS
Within sixty (60) days of entry of this Consent
22
Judgment,
23
$362,500.00
24
School of Pharmacy,
25
educational
26
Internal Revenue Code.
the Settling Defendants
shall pay the sum of
to the University of California
San Francisco,
organization
San Francisco
California,
a tax-exempt,
under Section 501(c)(3)
of the
27
28
12
II
PROP65
1
21.
The funds paid pursuant to Paragraph
2
in support of the School of Pharmacy's
3
related programs as specified
4
22.
the School of Pharmacy,
6
San Francisco,
1
(Attn. George L. Kenyon,
9
20 shall be used
lead research and lead-
in Exhibit F.
Payment shall be made by certified check dellvered
5
8
23.
University of Callfornia
San Francisco,
California
94143-0446
Dean).
Within sixty (60) days of entry of this Consent
Judgment,
the Settling Defendants
shall also pay the sum of
$60,000 to the California Public Health Foundation,
11
California,
12
Section 501(c)(3)
24.
a tax-exempt,
charitable organization
Berkeley,
under
of the Internal Revenue Code.
The funds paid pursuant to Paragraph
23 shall be used
14
for scientific,
15
educating
16
the risks of exposure to lead.
17
education,
prevention,
18
California
Public Health Foundation
19
experts
20
communication,
including prior consultation
21
representative
or designee of the Settling Defendants.
2Z
25.
educational,
and others about
and research program will be made by the
in consultation
with
and risk
with a
Payment shall be made by certified check delivered to
24
Suite 210, Berkeley,
25
General Counsel).
27
relating to
Specific decisions as to the
in public health, health education,
the California
26.
and research purposes
the public, health professionals,
23
26
Public Health Foundation,
California
94704
2001 Addison Street,
(Attn. James B. Simpson,
Within 60 days of entry of this Consent Judgment,
Settling Defendants shall also pay the sum of $322,500.00
28
MANGINI
to
--
10
13
News-18569
CONSENT JUDGMENT
13
the
in
PROP65
attorney fees and $50,000 in costs to Plaintiff's
27.
Payment shall be tendered
News-18570
attorneys.
jointly to Bushnell,
3
Caplan & Fielding and Milberg Weiss Bershad Specthrle & Lerach
4
and mailed to the attention of Alan M. Caplan,
5
Caplan & Fielding,
6
California
901 Market Street,
9
Suite 230, San Francisco,
94103.
7
8
Esq., Bushnell,
IV. ENTRY OF JUDGMENT
28.
This Consent Judgment shall be effective
determination
only upon the
by this Court, made on motion and with the
I0
opportunity
II
in the public interest.
12
Judgment will be binding unless and until this Consent Judgment
13
is entered.
14
15
for hearing,
that this is a good faith settlement
None of the terms of this Consent
V. MATTERS COVERED BY THIS CONSENT JUDGMENT
29.
This Consent Judgment is a full and final judgment and
16
settlement
applying to all Settllng Defendants and all
17
Subsidiary
Settling Parties
18
for all claims,
19
or causes of action under Proposition
20
Competition
21
that may apply to the facts alleged by Plaintiff or otherwise
22
may have arisen from any exposures
23
Products which may have occurred up to the date on which
24
warnings are required to be issued pursuant to Section II of
25
this Consent Judgment,
26
Consolidated
27
not in any way cover or resolve any claim alleged by the People
violations,
(as defined by Paragraph
actions,
damages,
31 below)
costs, penalties
65, the Unfair
Act, and any other statutes and causes of action
to lead in Leaded Crystal
including all violations
Complaints.
However,
28
14
alleged in the
this Consent Judgment does
PROP65
of the State of California
in Peopl e v. Baccarat,
2
S.F. Superior Court No. 932292 as to defendants
3
case as o ~ March 24, 1993.
4
30.
Upon entry of this Consent Judgment,
5
Defendants
6
Paragraph
l
agents,
8
the successors
9
from all claims,
and Subsidiary Settling Parties
31 below) and the directors,
parents,
affiliates,
Inc., et al.,
named in the
the Settling
(as defined by
officers,
divisions,
News-18571
employees,
and subsidiaries,
or assigns of any of them, are hereby released
violations,
actions,
damages,
costs,
IO
penalties,
11
may hereafter be asserted by Plaintiff or any other person,
12
corporation,
13
or in place of the Plaintiff.
14
31.
and
or causes of action set forth in Paragraph
29 which
or other entity whatsoever claiming by, through,
Subsidiary Settling Parties,
as used herein,
shall
15
mean the manufacturers,
16
and others who may be deemed responsible
17
persons to lead in Leaded Crystal Products manufactured
18
marketed by or acquired from a Settling Defendant.
Ig
from liability provided for by this Consent Judgment to such
20
Subsidiary Settling Parties shall extend only to liability
21
associated
22
manufactured
23
Settling Defendants and shall not extend to any liability
24
associated
25
entity.
26
27
distributors,
wholesalers,
retailers,
for exposures of
or
The release
with exposures to Leaded Crystal Products
or marketed by or acquired from one or more
with exposures to the products of a n y other party or
VI. ADDITIONAL ENFORCEMENT ACTIONS
32.
By entering into this Consent Judgment, Plaintiff does
28
MANGINI
CONSENT JUDGMENT
15
PROP65
News-18572
1
not waive any right to take further enforcement action on
Z
matters not covered by Section V of this Consent Judgment.
3
33.
4
diminishing
5
insure c o m p l i a n c e with Proposition
the Settling Defendants' continuing obligatlon
6
7
in this Consent Judgment shall be construed as
Nothing
65.
VII. ENFORCEMENT OF J U D G M E N T
34.
The terms and conditions
contained
in Section
8
herein shall be enforceable only and exclusively by the
9
California Attorney General's Office.
10
35.
Plaintiff
II
may, by motion or order to show cause before
11
the Superior Court of the City and County of San Francisco,
12
enforce
13
herein.
14
Consent Judgment,
15
penalties
the terms and conditions contained
in Section III
In any action brought by Plaintiff to enforce this
Plaintiff may seek whatever fines, costs,
or remedies are provided by law.
16
17
to
VIII. MODIFICATION OF JUDGMENT
36.
This Consent Judgment may be modified upon written
18
approval of Plaintiff and Settling Defendants or upon motion of
19
any party as provided by law for good cause shown.
20
IX. EXECUTION IN COUNTERPARTS
21
37.
22
counterparts
23
one and the same document.
This Consent Judgment may be executed
in one or more
which taken together shall be deemed to constitute
24
25
26
27
28
MANGINI C O N S E N T JUDGMENT
16
l
l
l
I
PROP65
News-18573
IT IS SO STIPULATED:
2
3
4
5
6
7
8
By
g
Alan M. Caplan
10
BUSHNELL, CAPLAN & FIELDING
Attorneys for Plaintiff
11
12
13
14
15
16
{
17
18
J
Ig
20
21
22
23
24
25
26
27
28
MANGINI
CONSENT
JUDGMENT
17
PROP65
2
News-18574
D a t e d : ....
3
4
By
Mich~le
B.
Corash'
5
MORRISON & FOERSTER
L e a d C o u n s e l for D e f e n d a n t s *
6
7
8
g
]0
I!
12
13
14
I5
16
17
18
Ig
20
21
22
23
24
25
26
27
28
*
Exhibit
executions.
MANGINI
G contains
CONSENT
the S e t t l i n g
JUDGMENT
Defendants'
individual
18
I
v
PROP65
News-18575
]
2
IT IS SO O R D E R E D ,
ADJUDGED,
A N D DECREED.
3
EDWARDSTERN
PRESiDInGJUDGE.
4
DATED:
5
i
i
J U D G E OF T H E S U P E R I O R
6
l
J3 /79
/
I0
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Z7
Z8
MANGINI
W81817
CONSENT JUDGMENT
19
COURT
,
EXHIBIT A
PROP65
News-18576
PROP65
News-18577
65
I
"..
o ! i e a O e o c r y s t a l e x p o s e s y o u t o i e a a , a c n e m l c a l K n o w n [ o [ n e ~ [ m e o~ L . a m o r m a
cause birth defects or other reproductive
ACCjq~ACC
Action
Industries/
International
American Glass
Works
Annahutte
Astral
Atlantis
Baccarat*
~
Badash
Beyer
Bohemia
Byrdes
C.A.L.P.
Capri
Cartier
Castle
Cavan
Cazlor
Ceska
Christian Dior
Christopher
Stuart
Cristal De
Sevres
Cristallerie
Zwiesel
Cristalleries de
Lorraine CL
Crystal Clear
Crystal Legends
Colle
Colony
Dansk
Dartington
Daum
DaVinci
Design Guild
Devon
Douhon
International
Dublin
Edinburgh
Emerald Isle
Euport
Fabrege
Fifth Avenue*
Fostoria
Oallia
Galway
Oodinger
Gorham
Hermes
Hofbauer
Home Beautiful
Hoya
Illusions
Imperlite
Imperlux
Inn
Irena
Irgia
]onai
Kagami
Kosta Boda*
Lalique
Legacy
Lenox
Leupold
Lorri
LS Collection
Magic
Marc Aurel
Marquis
Maxwdl
Mikasa
Miller Rogaska
Mozart
Nachtmann
Noritake
Ofnah
Oneida
Orrefors*
Oscar De
La Renta
Pasabahce
Polo/Ralph
Lauren*
Primavera Di
Cristallo
Riedd
Rogaska
Rosenthal
Royal Albert
Royal Brierley
Royal Crystal
Rock (RCR)
Royal Douhon
Royal Gallery
to
harm:
Royal Monarch
Saint Louis
Sasaki
Savoir Vivre
Schonwald
Schott
Sculptured
Slovakia
Spiegelau
St. Brendan
St. George
Stefan
Stolichnaya
Stuart
Studio Nova
Stylesetters
Svend Jensen
Thieresenthal
Thomas
Tfiomas Webb
Tiffany & Co.*
Tiffin
Tipperary
Toscany
Classics
Tudor
Tyrol*
Tyrone
Val Saint
Lambert
Vienna Design
Villeroy &
Boch
Waterford
Wedgwood
West Virginia
WMF
Zwiesei Ghss
*This marrfingdoes not applyto: Baccarat decanters,/lacons, stopperedpitchers, mustard and jam pots; Fi/th ,~wenueCrystalLTD "Ree/" collection;
Kosta Boda stem~vaTe and ser~'~vare; On'e/ors stemtuareand other greylabeled products; Polo/R.iph Lauren "Emma" and "Chairman" patterns; ~ffamj
Co. Classic W~neghusCollect/on;and Tyro/g/asswareand Ou~erture s t e m ~ r e .
......................
!
EXHIBIT B
PROP65
News-18578
PROP65
News-18579
EXHIBIT B
RETAILER INSTRUCTIONS
RE:
Court-ordered Warnings for Leaded Crystal Tableware
Dear Retailer:
Important materials concerning the need to provide
court-ordered warnings for certain leaded crystal tableware
products are attached to this letter.
This only applies to
products that are used for serving or storing food or
beverages.
Warnings are not required for figurines, vases
and other items which are not designed for use with food or
beverages.
It is very important that you read and follow
the instructions enclosed with this letter.
Enclosed are two very important items:
.
2.
Signs for posting in your store if, and only if t you
currently sell any leaded crystal tableware for which a
warninq is required.
The sign lists certain brands of
leaded crystal tableware products for which a warning
under Proposition 65 is to be provided.
Instructions for posting these signs.
If you do not post these signs by July 31, 1993 as
required, you risk further legal action by the Attorney
General or others, in which monetary penalties could be
sought.
These materials are being provided by leaded crystal
tableware manufacturers and distributors as part of a courtapproved settlement of a legal action brought under
"Proposition 65" by a private party.
In this legal action,
the private party claims that certain brands of leaded
crystal tableware contain lead, which passes into food and
drink kept or served in those items in excess of
Proposition 65 warning levels.
Lead is a chemical known to
-i-
PROP65
News-18580
the State-ho cause birth defects or other reproductive harm,
and the private party claims that manufacturers and
retailers of these products are legally required to provide
consumers with a clear and reasonable warning of this
exposure to lead.
The companies sued by the private party
dispute these claims, but have agreed to take various
actions to settle the case.
The leaded crystal tableware listed on the enclosed sign
may be sold legally because they comply w i t h international
standards for lead release.
They require a warning because
they exceed the stricter lead exposure standards of
Proposition 65.
Not all suppliers are participating in this courtordered warning program.
Suppliers that are not
participating in this program may be providing leaded
crystal tableware that requires a Proposition 65 warning.
You should contact your suppliers to determine if they are
in compliance with Proposition 6S, since failure to comply
could subject you to the legal actions referred to above.
-2-
Retail Store Warning
PROP65
News-18581
Instructions
Here's what you need to do to comply with the courtordered warning program:
i.
Check the listing of brands on the enclosed warning
sign, and see if any of the leaded crystal tableware sold in
your store is listed as requiring a warning.
If leaded
crystal tableware sold in your store is on the list, then
you must post the enclosed signs.
If your supplier of
another brand of leaded crystal tableware informs you that
its products require a warning, then you must also provide
warnings for those products.
If leaded crystal tableware
sold in your store is not on the list, and none of your
suppliers inform you that their products require a warning,
then you do not need. to provide warnings.
2.
Post the signs.
If any of the leaded crystal
tableware sold in your store appears on the list, then you
must post these signs by no later than July 31, 1993.
Where
you must post them depends on the type of store you operate.
There are three types:
a.
Department stores with a separate c h e c k - o u t
for the tableware department.
If you sell
leaded crystal tableware in a physically
separate section with its own cash registers
primarily used for that department, you must
post the signs at each cash register in the
tableware department and at two other
conspicuous places in the tableware
department.
b.
Large stores without separate check-out for
tableware.
If you have more than 7,500 square
feet of floor space, post a sign conspicuously
at each place where leaded crystal tableware
is displayed, plus any additional signs needed
to assure that any potential purchaser of
leaded crystal tableware is likely to see one
of the signs.
c.
Small stores with no separate check-out for
tableware.
If you have 7,500 square feet of
floor space or less, you may choose either
(a) or (b).
You do not need to do both.
W81910(21413/I)
-3-
E~IBIT c.
PROP65
News-18582
PROP65
News-18583
EXHIBIT C
MAIL ORDER HOUSE INSTRUCTIONS
RE:
c o u r t - o r d e r e d Warnings for Leaded Crystal Tableware
Products
Dear Mail Order House:
This letter conveys important materials concerning the
need to provide court-ordered warnings for certain leaded
crystal t a b l e w a r e products offered for sale to customers in
California.
This only applies to products that are used for
serving or storing food or beverages.
Warnings are not
required for figurines, vases and other items which are not
designed for use with food or beverages.
It is very
important that you read and follow the instructions enclosed
with this letter.
Enclosed are two very important items:
.
A sign listing certain brands of leaded crystal
tableware that contain lead, and for w h i c h a warning
under Proposition 65 is to be provided.
.
Instructions for providing warnings in either your
catalogs or brochures o_rr a warning a c c o m p a n y i n g your
products when they are shipped to California customers.
tableware manufacturers and distributors as part of a courtapproved s e t t l e m e n t of a legal action b r o u g h t under
"Proposition 65" by a private party.
In this legal action,
the private party claims that certain brands of leaded
crystal tableware contain lead, which passes into food and
drink kept or served in those items in excess of
Proposition 65 warning levels.
Lead is a chemical known to
the State to cause birth defects or other reproductive harm,
and the private party claims that m a n u f a c t u r e r s and
retailers of these products are legally required to provide
-i-
i
I
PROP65
News-18584
consumers w i t h a clear and reasonable warning of this
exposure to lead.
The companies sued by the private party
dispute these claims, but have agreed to take various
actions to settle the case.
If you do not provide these warnings by July 31, 1993 as
sought.
The leaded crystal tableware contained on the list may
be sold to California customers legally because it complies
with all international standards for lead release.
They
require a warning because they exceed the strict lead
exposure standards of california's Proposition 65.
crystal tableware products that require Proposition 65
warnings.
You should contact your suppliers to determine if
they are in compliance with Proposition 65, since failure to
comply could subject you to the legal actions referred to
above.
Sincerely,
/"
-2-
PROP65
News-18585
Mail Order Warning Instructions
Here's what you need to do to comply w i t h the courtordered w a r n i n g program:
i.
C h e c k the listing of brands on the enclosed sign,
and see if any of the leaded crystal t a b l e w a r e you are
offering for sale in California is listed as requiring a
warning.
If your leaded crystal tableware is on the list,
or if your s u p p l i e r of another brand of leaded crystal
tableware informs you that its products r e q u i r e a warning,
then you m u s t provide warnings.
If your leaded crystal
tableware is not on the list, and none of your other
suppliers inform you that its products require a warning,
then you do not need to provide warnings.
2.
Where necessary, begin providing w a r n i n g s by no
later than J u l y 31, 1993.
If you need to p r o v i d e warnings
you may do so in one of two ways.
a.
Mail Order Catalog .or Brochure.
The following
warning message shall be stated within the
mail order catalog or brochure, on the inside
front cover, on the same page as any order
form, or on the same page as the price, in at
least 12 point type:
"Prop 65 WARNING:
Use of the leaded
crystal tableware products for sale
in this catalog or brochure will
expose you to lead, a chemical known
to the State of California to cause
birth defects or other r e p r o d u c t i v e
harm."
If not all of the items for sale in the
catalog or brochure require a warning, the
following shall be used as an alternative to
the preceding warning message:
"Prop 65 WARNING:
Use of the
following brands of leaded crystal
tableware for sale in this catalog or
brochure will expose you to lead, a
chemical known to the State of
California to cause birth defects or
other reproductive harm:
[Insert
Listing of Brand Names and
Exceptions]."
--3--
b.
PROP65
News-18586
Package Insert or Label.
Alternatively, a
warning may be provided with the leaded
crystal tableware requiring a warning b y
(a) inserting a card or slip of paper
measuring at least 4" x 6" in the shipping
carton, or (b) affixing a p r e s s u r e - s e n s i t i v e
label measuring at least s t a n d a r d businesscard size on the shipping carton, or
(c) printing the warning on the packing slip
or customer invoice identifying that leaded
crystal tableware requiring a w a r n i n g in
letters of the same s i z e as the description of
the product.
The warning shall read as
follows:
"Prop 65 WARNING:
Use of this
product will expose you to lead, a chemical
known to the State of C a l i f o r n i a to cause
birth defects or other r e p r o d u c t i v e harm.
You
may return this product for full refund within
30 days of receipt, if you wish.
You may also
obtain a list of each brand of leaded crystal
tableware for which the same w a r n i n g is
given."
Upon request by the person receiving that warning, the mail
order house shall provide a list of brands of leaded crystal
tableware sold by you for which a warning is required.
-4-
E~IBIT D
PROP65
News-18587
PROP65
News-18588
PROP 65
t~
I-.4
t~
t-t
The particular pattern of
crystal stemware used here will expose you
to lead, a chemical known to the
State of California to cause birth defects or
other reproductive harm.
<
t~
EXHIBIT E
PROP65
News-18589
PROP65
EXHIBIT
News-18590
E
INSTRUCTIONS TO R E S T A U R A N T S U P P L I E R S
RE:
C o u r t - o r d e r e d Warnings for Leaded Crystal Tableware
Products
Dear R e s t a u r a n t Supplier:
Important material for your restaurant customers
c o n c e r n i n g the need to provide c o u r t - o r d e r e d warnings for
certain leaded crystal tableware products is attached to
this letter.
These materials contain a list of certain
brands of leaded crystal tableware products for which a
P r o p o s i t i o n 65 warning is to be provided.
You are requested
to send the enclosed materials to each r e s t a u r a n t that uses
leaded crystal tableware on this list.
!
l
m a n u f a c t u r e r s and distributors as part of a c o u r t - a p p r o v e d
settlement of a legal a c t i o n brought under Proposition 65 by
a private party.
In this legal action, the private party
claims that certain brands of leaded crystal tableware
contain lead, which passes into food and d r i n k kept in or
served in those items in excess of Proposition 65 warning
levels.
Lead is a chemical known to the State to cause
birth defects or other r e p r o d u c t i v e harm, and the private
party claims that manufacturers and retailers of these
products are legally required to provide consumers with a
clear and reasonable warning of this exposure to lead.
The
companies sued by the private party dispute these claims,
but have agreed to take various actions to settle the case.
If you do not send these materials by J u l y 31, 1993 as
requested, you risk further legal action by the Attorney
sought.
The leaded crystal tableware brands c o n t a i n e d on this
list may be sold and used in restaurants legally because
they comply with all international standards for lead
release.
They require a warning because they exceed the
-i-
strict lead exposure warning standards
Proposition 65.
PROP65
News-18591
of California,s
Not all leaded crystal suppliers are participating in
this court-ordered warning program.
warnings.
above.
Sincerely,
i
-2-
PROP65
News-18592
RESTAURANT INSTRUCTIONS
RE:
Court-ordered
Products
Warnings
for Leaded Crystal
Tableware
Dear R e s t a u r a n t e u r :
Important material concerning the need to provide courtordered warnings for certain leaded crystal tableware is
attached to this letter.
It is very important that you read
and follow these instructions.
Enclosed is:
i) a listing of certain leaded crystal
brands of tableware products for which a warning under
Proposition 65 is to. be provided, and 2) a sign for posting
in your restaurant (or other food service establishment) if,
and only if, you currently use any leaded crystal tableware
for which a warning is required.
You must post this sign
where it will be seen by your customers before they consume
food, such as near the main entrance, or near where people
wait to be seated.
These signs are being provided by leaded crystal
manufacturers and distributors as part of a court-approved
settlement of a legal action brought under Proposition 65 by
a private party.
In this legal action, the private party
claims that certain brands of leaded crystal tableware
contain lead, which passes into food and drink kept or
served in those items in excess of Proposition 65 warning
levels.
Lead is a chemical known to the State to cause
birth defects or other reproductive harm, and the private
party claims that manufacturers and retailers of these
products are legally required to provide consumers with a
clear and reasonable warning of this exposure to lead.
The
~ompanies sued by the private party dispute these claims,
but have agreed to take various actions to settle the case.
If you do not post this sign by July 31, 1993 as
General, or others in which monetary penalties could be
sought.
The leaded crystal tableware products contained on the
list may be used in your restaurant legally because they
comply with all international standards for lead release.
They require a warning because they exceed the strict lead
exposure standards of California,s Proposition 65.
-3-
PROP65
News-18593
warnings.
above.
Sincerely,
W81913(21413/i)
-4-
PROP65
News-18594
PROP65
News-18595
EXHIBIT F
USE OF FUNDING TO UCSF SCHOOL OF PHARMACY
!
Funding provided to the University of California, San
Francisco, School of Pharmacy ("the School"), shall be used for
lead-related research and educational activities in accordance
with the following provisions~
l
!
i
1. The School will not substitute these funds for other funds
available for the same activities.
!
2.
In order to avoid duplication of effort, the School will
consult with the California Public Health Foundation regarding
any program this is specifically directed to the public (e.g.,
the San Francisco Ray Area Regional Control Center program
described below).
3. Annually, the School will provide to the Attorney General a
report on the use of the funds on a fiscal year basis (i.e.,
July 1 to June 30).
4. In light of the fact that basic research in any heavy metal
(e.g., arsenic, mercury, etc.) can provide important clues to our
understanding of the biological effects (etc.,) of lead and other
heavy metals, "lead-related research" permitted for these funds
may include research in heavy metals, but will be restricted to
that end.
5. Funds shall be spent in accordance with the following plan
over the next two years~
a°
The School will initiate a two-year, 10 county-wide program
of support and expansion of the San Francisco Bay Area
Regional Control Center programs focusing on lead exposure,
including identification of population clusters likely to be
exposed to high levels of lead, common environment and/or
commercial lead sources, and development and presentation of
appropriate preventive educational materials and programs.
Funding for this component of the program shall be $60,000
per year for two years.
b.
The School will equip the laboratory of a new faculty member
who is committed to heavy metal research.
This equipment is
essential for startup in this area and shall be dedicated
entirely to her use and control.
(No other funds are
available for this purpose.)
Funding for this component of
the program shall be $50,000 in the first year only.
C.
The School will establish a total of four "lure" stipends
(ideally, two per year for a period of two years.).
These
stipends will be specifically designated for the support of
developing researchers who agree to undertake research in
.~
PROP65
News-18596
the heavy metal area. Funding for these stipends shall be
$45,430 per year for two years.
d.
e.
I
The School will fund, on a competitive grant basis, seedmoney projects submitted by School of Pharmacy faculty or
graduate students for basic research in heavy metals.
All
grant proposals will be peer-reviewed and approved by the
School's Graduate Instruction and Research Committee.
(A
brief description of the projects funded will be included
with the annual budget report described above.)
Funding for
this component of the program shall be $50,820 per year for
t w o years.
Alterations in this spending plan shall be approved by the
Attorney General.

bun 21 ystal ltd. - Prop 65 News Documents

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