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1 11 Angeles County; Michael N. Feuer, City Attorney of Los Angeles; Kimberly Lewis, District 2 Attorney of Merced County; Todd Spitzer, District Attorney of Orange County; Michael A. Hestrin, 3 District Attorney of Riverside County; Anne Marie Schubert, District Attorney of Sacramento 4 County; Jason Anderson, District Attorney of San Bernardino County; Summer Stephan, District 5 Attorney of San Diego County; Tori Verber Salazar, District Attorney of Sar. Joaquin County; 6 Stephen M. Wagstaffe, District Attorney of Sap. Mateo County; Joyce E. Dudley, District Attorney of 7 Santa Barbara County; Jeffrey F. Rosen, District Attorney of Santa Clara County; Krishna A. 8 Abrams, District Attorney of Solano County; Jill R. Ravitch, District Attorney of Sonoma County; 9 Birgit A. Fladager, District Attorney of Stanislaus County; Tim Ward, District Attorney of Tulare 10 1 County; Gregory D. Totten, District Attorney of Ventura County, and Jeff W. Reisig, District 11 Attorney of Yolo County (collectively, "the People"). 12 1 2. The People bring this action to, among other things, enjoin Defendant from violating 13 Chapters 6.5 and 6.95 of Division 20 of the Health and Safety Code, and to impose civil penalties 14 11 against Defendant. 15 11 3. The People may bring a civil action to enjoin any violation of Chapter 6.5 of Division 16 20 of the Health and Safety Code ("Chapter 6.5") and may seek civil penalties for any violation of 17 II Chapter 6.5. (Health & Saf. Code, § 25182; see also Health & Saf. Code, §§ 25181, 25189, 18 25189.2.) 19 I I 4. The People may bring a civil action to enjoin any violation of Health and Safety Code 20 sections 25504 to /25508.2, inclusive, and Section 1.5511 (collectively, "Chapter 6.95"), and may seek 21 civil penalties for any violation of Chapter 6.95. (Health & Saf. Code, § 25515.7; see also Health & 22 II Saf. Code, §§ 25515, 25515.2, 25515.5, subd. (b), 25515.6.) 23 11 5. The People may bring a civil action to enjoin any person who engages, has engaged, 24 or proposes to engage in unfair competition, as defined in Business and Professions Code section 25 I 117200, and may seek civil penalties for each act of unfair competition. (Bus. & Prof Code, §§ 26 1117203, i 7204; 17206:) 27 11 6. The People bring this action without prejudice to any other action or claim that the 28 People may have based on separate, independent, and unrelated violations arising out of matters or -2- COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL PENALTIES, AND OTHER RELIEF