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1 b. Engaging in any acts in violation of Health and Safety Code sections 25500 et seq., <br /> 2 including but not limited to: <br /> 3 1. Violation of Health and Safety Code section 25505(a)(2); <br /> 4 2. Violation of Health and Safety Code section 25505(a)(4); and <br /> 5 3. Violation of Health and Safety Code section 25505(a)(4). <br /> 6 c. Engaging in any of the unlawful acts of unfair competition set forth in the Third <br /> 7 Cause of Action of this Complaint, as well as any other violations of the Business and Professions <br /> 8 Code, section 17200 et seq., including but not limited to: <br /> 9 1. Violation of Health and Safety Code sections 25100 et seq., as described in <br /> 10 paragraphs 8 —8(d) above; and <br /> 11 2. Violation of Health and Safety Code sections 25500 et seq., as described in <br /> 12 paragraphs 9—9(c) above. <br /> 13 2. For violation of the First Cause of Action, that Defendants herein be assessed a civil <br /> 14 penalty of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), for each violation, in an amount <br /> 15 according to proof, pursuant to Health and Safety Code section 25189.2(b). <br /> 16 3. For violation of the Second Cause of Action, that Defendant herein be assessed a civil <br /> 17 penalty of TWO THOUSAND DOLLARS ($2,000.00), for each violation per day in which the <br /> 18 violation occurred, except as to those knowing violations for which a civil penalty of FIVE <br /> 19 THOUSAND DOLLARS ($5,000.00), for each violation per day should be assessed in a total <br /> 20 amount according to proof,pursuant to Health and Safety Code sections 25515(a) and 25515(b). <br /> 21 4. For violation of the Third Cause of Action, that Defendants herein be assessed a civil <br /> 22 penalty of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00), for each act of unfair <br /> 23 competition, including but not limited to the violation of the court's injunction,in an amount <br /> 24 according to proof,pursuant to Business and Professions Code, section 17206. <br /> 25 5. For investigative, enforcement, and litigation costs incurred by both the Plaintiff and the <br /> 26 investigating agency. <br /> 27 6. For such other and further relief to the Plaintiff and investigating agency as the nature of <br /> 28 the case may require and that the court deems proper to fully dissipate the effects of the unlawful and <br /> -5- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />