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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 />66262.130(c)(2); <br />66262.130(c)(3); and <br />5. Violation of California Code of Regulations, title 22 section 66262.34(f); <br />6. Violation of California Code of Regulations, title 22 section <br />7. Violation of California Code of Regulations, title 22 section <br />8. Violation of California Code of Regulations, title 22 section <br />66262.130(c)(5). <br />b. Engaging in any of the unlawful acts of unfair competition set forth in the First <br />Cause of Action of this Complaint, as well as any other violations of the Business and Professions <br />Code, section 17200 et seq., including but not limited to: <br />1. Violation of Health and Safety Code section 25100 et seq., as described in <br />paragraphs 11-11(h) above. <br />2. For violations within the First Cause of Action, that Defendants herein be assessed a civil <br />penalty of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount <br />according to proof, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), <br />pursuant to Health and Safety Code section 25189.2(b). <br />3. For violations within the Second Cause of Action, that Defendants herein be assessed a <br />civil penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br />competition, but not less than ONE HUNDRED THOUSAND DOLLARS ($100,000.00), in an <br />amount according to proof, pursuant to Business and Professions Code, section 17206. <br />4. For investigative, enforcement, and litigation costs incurred by both the Plaintiff and the <br />investigating agency. <br />5. For such other and further relief to the Plaintiff and investigating agency as the nature of <br />-5- <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />