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