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1 <br />1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />Olt <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 />$2,000.00 for each day in which the violation occurred, pursuant to Health and Safety Code <br />section 25514, subdivision (a). <br />44. As a consequence of Defendant's knowing violation of any of these sections, <br />Defendant is liable for a civil penalty that must be imposed for each separate violation in an <br />amount up to $5,000.00 for each day in which the violation occurred, pursuant to Health and <br />Safety Code section 25514, subdivision (b). <br />45. Based on the above, the People request injunctive relief against Defendant under <br />Health and Safety Code sections 25516 and 25516.2, as described in the People's prayer for <br />relief. <br />FIFTH CAUSE OF ACTION <br />(Violations of Unfair Competition Laws) <br />(Business & Professions Code sections 17200, et seq.) <br />46. Plaintiff realleges paragraphs 1 through 45, inclusive. <br />47. Within four (4) years of the date of commencement of this action, exclusive of the <br />Tolling Period set forth in paragraph 13 herein, Defendant has engaged in unlawful acts, <br />omissions, and practices that constitute unfair competition within the meaning of Business and <br />Professions Code sections 17200 through 17208 including, but not limited to, the acts or <br />omissions and practices alleged in the First through Fourth Causes of Action, above, and unless <br />enjoined by order of the Court, Defendant may or will continue in the course of conduct as <br />alleged herein. <br />48. Each and every separate act constitutes an unlawful and/or unfair business <br />practice. Each day that Defendant engaged in each separate unlawful act, omission or practice is <br />a separate and distinct violation of Business and Professions Code section 17200. <br />49. Pursuant to Business and Professions Code section 17206, Defendant is liable for <br />civil penalties for each and every separate act of unfair competition as alleged herein. <br />50. Defendant must be immediately and permanently enjoined, pursuant to Business <br />and Professions Code section 17203, from engaging in acts or practices that, as alleged in this <br />Complaint, violate Chapter 6.5 and/or 6.95 of Division 20 of the Health and Safety Code and their <br />implementing regulations, Health and Safety Code section 117600 et seq., and county and local <br />13 <br />Complaint For Permanent Injunction, Civil Penalties And Other Equitable Relief <br />