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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />iv <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 />25 <br />27 <br />28 <br />Court, Defendant may or will continue in the course of conduct as alleged in this Complaint. <br />56. In addition to the acts alleged in the First through Fourth Causes of Action above, <br />Defendant has engaged in, and continues to engage in, acts or practices that violated Civil Code <br />section 1798.81 by disposing of customer records without shredding, erasing, or otherwise modifying <br />the personal information in those records to make it unreadable or undecipherable through any <br />means. <br />57. Each and every separate violative act as alleged herein constitutes an unlawful, <br />fraudulent and/or unfair business practice and is a separate and. distinct violation of Business and <br />Professions Code section 17200 et seq. <br />58. Based on the above, the People request injunctive relief against Defendant under <br />Business and Professions Code section 17203, and civil penalties under Business and Professions <br />Code section 17206, as described in the People's prayer for relief. <br />PRAYER <br />WHEREFORE, the People respectfully request that the Court grant the following relief: <br />1. Permanently enjoin Defendant from violating those provisions of Chapter 6.5 of <br />Division 20 of the Health and Safety Code and its implementing regulations, which Defendant is <br />alleged to have violated; <br />2. Permanently enjoin Defendant from violating those provisions of Chapter 6.95 of <br />Division 20 of the Health and Safety Code and its implementing regulations, which Defendant is <br />alleged to have violated; <br />3. Permanently enjoin Defendant from engaging in unfair competition as defined in <br />Business and Professions Code section 17200, including those acts alleged in paragraph 32 of this <br />Complaint — including those acts that violate the provisions of Health and Safety Code sections <br />25100, et seq., 25500 et seq., and Civil Code section 1798.8 1, which thereby constitute unfair <br />competition within the meaning of Business and Professions Code section 17200; <br />4. Assess a civil penalty against Defendant for each violation of Health and Safety Code <br />section 25189, or alternatively, section 25189.2, in an amount according to proof; <br />5. Assess a civil penalty against Defendant pursuant to Health and Safety Code section <br />-17- <br />COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL PENALTIES, AND OTHER RELIEF <br />