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I Angeles County; Michael N. Feuer, City Attorney of Los Angeles; Kimberly Lewis, District
<br /> 2 Attorney of Merced County; Todd Spitzer, District Attorney of Orange County; Michael A. Hestrin,
<br /> 3 District Attorney of Riverside County; Anne Marie Schubert,District Attorney of Sacramento
<br /> 4 County; Jason Anderson, District Attorney of San Bernardino County; Summer Stephan, District
<br /> 5 Attorney of San Diego County; Tori Verber Salazar,District Attorney of Sar.Joaquin County;
<br /> 6 Stephen M. Wagstaffe, District Attorney of Sap.Mateo County; Joyce E. Dudley, District Attorney of
<br /> 7 Santa Barbara County; Jeffrey F. Rosen,District Attorney of Santa Clara County; Krishna A.
<br /> 8 Abrams, District Attorney of Solano County; Jill R. Ravitch, District Attorney of Sonoma County;
<br /> 9 Birgit A. Fladager, District Attorney of St and County; Tim Ward, District Attorney of Tulare
<br /> 10 County; Gregory D. Totten, District Attorney of Ventura County, and Jeff W. Reisig, District
<br /> 11 Attorney of Yolo County(collectively, "the People").
<br /> 12 2. The People bring this action to, among other things, enjoin Defendant from violating
<br /> 13 Chapters 6.5 and 6.95 of Division 20 of the Health and Safety Code, and to impose civil penalties
<br /> 14 against Defendant.
<br /> 15 3. The People may bring a civil action to enjoin any violation of Chapter 6.5 of Division
<br /> 16 20 of the Health and Safety Code("Chapter 6.5") and may seek civil penalties for any violation of
<br /> 17 Chapter 6.5. (Health& Saf. Code, § 25182; see also Health & Saf. Code, §§ 25181, 25189,
<br /> 18 25189.2.)
<br /> 19 4. The People may bring a civil action to enjoin any violation of Health and Safety Code
<br /> 20 sections 25504 to 25508.2,inclusive, and Section 25511 (collectively, "Chapter 6.95"), and may seek
<br /> 21 civil penalties for any violation of Chapter 6.95. (Health& Saf. Code, § 25515.7; see also Health&
<br /> 22 Saf. Code, §§ 25515, 25515.2, 25515.5, subd. (b), 25515.6.)
<br /> 23 5. The People may bring a civil action to enjoin any person who engages,has engaged,
<br /> 24 or proposes to engage in unfair competition, as defined in Business and Professions Code section
<br /> 25 17200, and may seek civil penalties for each act of unfair competition. (Bus. &Prof Code, §§
<br /> 26 117203, 17204, 17206z)
<br /> 27 6. The People bring this action without prejudice to any other action or claim that the
<br /> 28 People may have based on separate, independent, and unrelated violations arising out of matters or
<br /> I
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<br /> COMPLAINT FOR INJUNCTIVE RELIEF,CIVIL PENALTIES,AND OTHER RELIEF
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