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1 ` <br /> 1 21. Pursuant to California Business and Professions Code Section 17206,the <br /> 2 Defendant is liable for civil penalties for each act or practice of unfair competition. <br /> 3 22. Defendant must immediately and permanently be enjoined from engaging in any <br /> 4 act or practice that violates Chapters 6.5 and 6.95 of Division 20 of the California Health and <br /> 5 Safety Code and their implementing regulations,at the Covered Facilities and which therefore <br /> 6 constitutes"unfair competition"within the meaning of California Business and Professions <br /> 7 Code Section 17200. <br /> 8 WHEREFORE,PLAINTIFF PRAYS FOR THE FOLLOWING RELIEF: <br /> 9 1. A Permanent Injunction requiring Defendant to comply with the requirements of <br /> 10 California Health and Safety Code,Division 20,Chapter 6.5; <br /> 11 2. A Permanent Injunction requiring Defendant to comply with California Health <br /> 12 and Safety Code,Division 20,Chapter 6.95; <br /> 13 3. A Permanent Injunction prohibiting Defendant from engaging in any act that <br /> 14 violates Chapter 6.5 or 6.95 of Division 20 of the California Health and Safety Code,or their <br /> 15 implementing regulations,which thereby constitutes"unfair competition"within the meaning of <br /> 16 California Business and Professions Code Section 17200; { <br /> 17 4. Civil penalties according to proof against Defendant,pursuant to California i <br /> 18 Health and Safety Code Section 25189; <br /> 19 5. Civil penalties according to proof against Defendant,pursuant to California <br /> 20 Health and Safety Code Section 25189.2; <br /> 21 6. Civil penalties according to proof against Defendant,pursuant to California <br /> S <br /> 22 Health and Safety Code Section 25514; <br /> 23 7 Civil penalties according to proof against Defendant,pursuant to California <br /> 24 Business and Professions Code Section 17206 for each act of unfair competition engaged in by <br /> 25 Defendant; <br /> 26 8. Grant Plaintiff its costs of inspection,investigation,attorney's fees,enforcement, <br /> 27 prosecution,and suit,herein;and <br /> 28 9. Grant such other and further relief to Plaintiff as the court deems just and proper <br /> COMPLAINT FOR INJUNCTION,CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />