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i <br /> 1 <br /> 2 <br /> 3 PRAYER <br /> 4 WHEREFORE, Plaintiff prays that: <br /> 5 1. Defendants be permanently restrained and enjoined from engaging in or performing, <br /> 6 directly or indirectly, any and all of the following acts: <br /> 7 a. Engaging in any acts in violation of Health and Safety Code section 25100 et seq., <br /> 8 including but not limited to: <br /> 9 1. Violation of Health and Safety Code section 25160.2(b)(3); <br /> 10 2. Violation of California Code of Regulations, title 22 section 66262.12(a); <br /> 11 3. Violation of California Code of Regulations,title 22 section 66262.34(d); <br /> 12 4. Violation of California Code of Regulations, title 22 section 66262.34(f); <br /> 13 5. Violation of California Code of Regulations,title 22 section 66262.40(a); <br /> 14 b. Engaging in any acts in violation of Health and Safety Code, section 25280 et seq., <br /> 15 including but not limited to: <br /> 16 1. Violation of Health and Safety Code section 25292.2(a); <br /> 17 2. Violation of California Code of Regulations,title 23 section 2715(e); <br /> 18 3. Violation Health and Safety Code section 25291(b); <br /> 19 c. Engaging in any of the unlawful acts of unfair competition set forth in the Second <br /> 20 Cause of Action of this Complaint, as well as any other violations of the Business and Professions <br /> 21 Code, section 17200 et seq., including but not limited to: <br /> 22 1. Violation of Health and Safety Code section 25100 et seq., as described in <br /> 23 paragraph 10- I Oe above; <br /> 24 2. Violation of Health and Safety Code section 25280 et seq., as described in <br /> 25 paragraph 11 - l lc above; <br /> 26 2. For violation of First Cause of Action,that Defendants herein be assessed a civil penalty of <br /> 27 TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation,in an amount according <br /> 28 to proof,but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), pursuant to <br /> 5 <br /> VERIFIED COMPLAINT <br />