11.   The complaint charges that the Occupational Health and Safety Administration has flouted Nafta by failing to adequately enforce safety laws to protect apple workers from pesticides.

12.   The complaint charges the defendants with making false or misleading statements to persuade customers to buy credit insurance.

13.   The complaint also charges discrimination in pay and treatment.

14.   The complaint also charges that the company failed to properly contain wastewater run-off and violated state surface water quality standards.

15.   The complaint also charges that workers were harassed for speaking their native language.

16.   The complaint charged that Schwartz Smith sent letters to the customers falsely reporting that accounts had been established in their names and their money had been invested in stocks.

17.   The complaint charges Hill with theft of government property and obstruction of justice.

18.   The complaint will also charge him with one count of criminal possession of a weapon, she said.

19.   The complaint charged Coates with one count of mail fraud in connection with his solicitation of investors.

20.   The complaint charges Avant!