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