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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />paragraphs 11 — 11 f above. <br />2. For violation of the First Cause of Action, that Defendants herein be assessed a civil <br />penalty of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount <br />according to proof, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), <br />pursuant to Health and Safety Code section 25189.2(b). <br />3. For violation of the Second Cause of Action, that Defendants herein be assessed a civil <br />penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br />competition, including but not limited to the violation of the court's injunction, in an amount <br />according to proof, but not less than FIFTY THOUSAND DOLLARS ($50,000.00), pursuant to <br />Business and Professions Code, section 17206. <br />4. Plaintiff recover its costs and agencies costs. <br />5. Plaintiff have such other and further relief as the nature of the case may require and <br />that the court deems proper to fully dissipate the effects of the unlawful and unfair acts complained <br />of herein. <br />Dated: /�a ,11 <br />Respectfully submitted, <br />JAMES P. WILLETT <br />DISTRICT ATTORNEY <br />By: CELESTE KAISCH <br />Deputy District Attorney <br />-5- <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />