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I Court, Defendant may or will continue in the course of conduct as alleged in this Complaint. 2 56. In addition to the acts alleged in the First through Fourth Causes of Action above, 3 Defendant has engaged in, and continues to engage in, acts or practices that violated Civil Code 4 section 1798.81 by disposing of customer records without shredding, erasing, or otherwise modifying 5 the personal information in those records to make it unreadable or undecipherable through any 6 means. 7 57. Each and every separate violative act as alleged herein constitutes an unlawful, 8 fraudulent and/or unfair business practice and is a separate and.distinct violation of Business and 9 Professions Code section 17200 et seq. i V 58. Based on the above, the People request injunctive relief against Defendant under 11 Business and Professions Code section 17203, and civil penalties under Business and Professions 12 Code section 17206, as described in the People's prayer for relief. 13 PRAYER 14 WHEREFORE,the People respectfully request that the Court grant the following relief: 15 1. Permanently enjoin Defendant from violating those provisions of Chapter 6.5 of 16 Division 20 of the Health and Safety Code and its implementing regulations,which Defendant is 17 alleged to have violated; 18 2. Permanently enjoin Defendant from violating those provisions of Chapter 6.95 of 19 Division 20 of the Health and Safety Code and its implementing regulations,which Defendant is 20 alleged to have violated; 21 3. Permanently enjoin Defendant from engaging in unfair competition as defined in 22 Business and Professions Code section 17200,including those acts alleged in paragraph 32 of this 23 Complaint—including those acts that violate the provisions of Health and Safety Code sections 24 25100,et seq., 25500 et seq., and Civil Code section 1798.8 1, which thereby constitute unfair 25 competition within the meaning of Business and Professions Code section 17200; 25 4. Assess a civil penalty against Defendant for each violation of Health and Safety Code 27 section 25189, or alternatively, section 25189.2, in an amount according to proof; 28 5. Assess a civil penalty against Defendant pursuant to Health and Safety Code section - 17- COMPLAINT FOR INJUNCTIVE RELIEF,CIVIL PENALTIES,AND OTHER RELIEF