COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

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1 15. Plaintiff is informed and believes and based on such information and belief alleges that 2 beginning at an exact date that is unknown to plaintiff,but within four(4)years prior to the filing of this 3 complaint, defendants have engaged in acts of unlawful and/or unfair competition prohibited by 4 California Business and Professions Code §17200 - §17208 by virtue of the acts described herein, each 5 of which constitutes an unfair and/or unlawful business practice. These acts include but are not limited 6 to: 7 16. Violation of Health and Safety Code § 25503.5 and § 25505 as further described in the First 8 Cause of Action herein. 9 PRAYER 10 WHEREFORE, Plaintiff prays that: 11 1. Defendants be permanently restrained and enjoined from engaging in or performing, directly 12 or indirectly, any and all of the following acts: 13 (a) Engaging in any of the unlawful acts of unfair competition set forth in the First and 14 Second Cause of Action of this complaint, as well as any other violations of Business and Professions 15 Code §17200 - §17208. 16 (b) Violating Health and Safety Code §§ 25503.5 and/or 25505. 17 2. For violations of the Second Cause of Action, that defendants herein be assessed a civil 18 penalty of TWO THOUSAND DOLLARS ($2,000.00), for each day a violation of Health and Safety 19 Code Sections 25503.5 or 25505 except as to those knowing violations for whibh a civil penalty of FIVE 20 THOUSAND DOLLARS ($5,000.00)per day should be assessed in a total amount according to proof 21 but no less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00). 22 3. Defendants herein be assessed a civil penalty of TWO THOUSAND FIVE HUNDRED 23 DOLLARS ($2,500.00) for each act of unfair competition, in an amount according to proof but not less 24 than ONE HUNDRED THOUSAND DOLLARS ($100,000.00),pursuant to Business and Professions 25 Code §17206; 26 4. Plaintiff recover its costs. 27 HI 28 4.