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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <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 />Complaint. violate Chapters 6.5, 6.7 and 6.95 of Division 20 of the Health and Safety Code and <br />implementing regulations, and which thereby constitute unfair competition within. the meaning of <br />Business and Professions Code section 17200.. <br />PRAYER FOR RELIEF <br />F <br />The People request: <br />1. A Permanent Injunction requiring Wal-Mart to comply with those provisions of <br />Health and Safety Code, Division 20, Chapter 6.5 and implementing regulations, which Wal-Mart <br />is alleged to have violated; <br />2, AP6nnaftentInJunotion requiring Wal-Mart to comply with those provisions of <br />Health <br />-iealthan4,:S.9&ty Godo, Division 20, Chapter 63 and implementing regulations; which Walwmart <br />is alleged to have Molatod- <br />3, A. Permanent Injunction requiring Wal-Mart to comply, with those provi.giom of <br />.Health and Safety Code, Division 20, Chapter 6.95 and implementing regulations, which Wal- <br />Mart is alleged to have violated, <br />4. A Permanont Injunction, issued pursuant to Business and Professions Code <br />section 17203, prohibiting Wal-Mart from engaging in activity that violates die provisions of <br />Chapters 6.5, 6.7 or 6.95 of Division 20 of the Health and Safety Code, as alleged itithis <br />complaint which thereby constitute unfair competition. within the noeaning of Business and <br />Professions Code section 17200; <br />5. Civil penalties according to proof against Wal- Martpursuant to Health and Safety <br />Code section 25189, or alternatively section 25189.2, in an amount according to proof-, <br />6. Civil penalties according to proof against Wal-Mart pursuant to Realth and Safety <br />Code section 25514, in an amount according to proof; <br />7 Civil penalties according to proof against Wal-Mart pursuant to Business and <br />Professions Code section 17206 for each act of unfair competition engaged in by Wal-Mart, in an <br />amount according to proof, <br />8 Plaintiff s cost of inspection, investigation, attorneys fees, enforcement, <br />prosecution, and suit herein, including but not limited to such costs as are authorized for <br />reimbursement pursuant to Code of Civil Procedure section 1021.8; and, <br />17 <br />COMPLAINT FOR PEIMANENT INJUNCTION, CfVIL PFNALTtES AND OTHER EQUITABLE RELIEF <br />