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1 b. Engaging in any acts in violation of Health and Safety Code sections 25500 et seq., <br />2 including but not limited to: <br />3 1. Violation of Health and Safety Code section 25505(a)(2); <br />4 2. Violation of Health and Safety Code section 25505(a)(4); and <br />5 3. Violation of Health and Safety Code section 25505(a)(4). <br />6 c. Engaging in any of the unlawful acts of unfair competition set forth in the Third <br />7 Cause of Action of this Complaint, as well as any other violations of the Business and Professions <br />8 Code, section 17200 et seq., including but not limited to: <br />9 1. Violation of Health and Safety Code sections 25100 et seq., as described in <br />10 paragraphs 8 — 8(d) above; and <br />11 2. Violation of Health and Safety Code sections 25500 et seq., as described in <br />12 paragraphs 9 — 9(c) above. <br />13 2. For violation of the First Cause of Action, that Defendants herein be assessed a civil <br />14 penalty of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount <br />15 according to proof, pursuant to Health and Safety Code section 25189.2(b). <br />16 3. For violation of the Second Cause of Action, that Defendant herein be assessed a civil <br />17 penalty of TWO THOUSAND DOLLARS ($2,000.00), for each violation per day in which the <br />18 violation occurred, except as to those knowing violations for which a civil penalty of FIVE <br />19 THOUSAND DOLLARS ($5,000.00), for each violation per day should be assessed in a total <br />20 amount according to proof, pursuant to Health and Safety Code sections 25515(a) and 25515(b). <br />21 4. For violation of the Third Cause of Action, that Defendants herein be assessed a civil <br />22 penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br />23 competition, including but not limited to the violation of the court's injunction, in an amount <br />24 according to proof, pursuant to Business and Professions Code, section 17206. <br />25 5. For investigative, enforcement, and litigation costs incurred by both the Plaintiff and the <br />26 I investigating agency. <br />27 6. For such other and further relief to the Plaintiff and investigating agency as the nature of <br />28 the case may require and that the court deems proper to fully dissipate the effects of the unlawful and <br />-5- <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF