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1 2. Violation of Health and Safety Code section 25506(a). 2 b. Engaging in any of the unlawful acts of unfair competition set forth in the Third 3 Cause of Action of this Complaint, as well as any other violations of the Business and Professions 4 Code, section 17200 et seq., including but not limited to: 5 1. Violation of Health and Safety Code sections 25500 et seq., as described in 6 paragraphs 8--8(c) above. 7 2. For violation of the First Cause of Action, that Defendant herein be assessed a civil 8 penalty of TWO THOUSAND DOLLARS ($2,000.00), for each violation per day in which the 9 violation occurred, except as to those knowing violations for which a civil penalty of FIVE 10 THOUSAND DOLLARS ($5,000.00), for each violation per day should be assessed in a total 11 amount according to proof,pursuant to Health and Safety Code sections 25515(a) and 25515(b). 12 3. For violation of the Second Cause of Action, that Defendants herein be assessed a civil 13 penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair 14 competition, including but not limited to the violation of the court's injunction, in an amount 15 according to proof, pursuant to Business and Professions Code, section 17206. 16 4. For investigative, enforcement, and litigation costs incurred by both the Plaintiff and the 17 investigating agency. 18 5. For such other and further relief to the Plaintiff and investigating agency as the nature of 19 the case may require and that the court deems proper to fully dissipate the effects of the unlawful and 20 unfair acts complained of herein. 21 Dated: ��$'I� Respectfully submitted, 22 TORI VERBER SALAZAR DISTRICT ATTORNEY 23 24 - By: 25 KELLY R. M IEL 26 Deputy District ttorney 27 28 -4— VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF