The People of the State of California vs. Jasdip Boyal

Complaint Information

FRESNO COUNTY SUPERIOR COURT

By: A. Ramos, Deputy

ATTORNEYS FOR PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF FRESNO

THE PEOPLE OF THE STATE OF Civil Case No.: 18CECG02018 CALIFORNIA., D.A. Case No.: 2017-B-9315 Plaintiff, COMPLAINT INJUNCTION, CIVIL PENALTIES, INJUNCTIVE AND v. OTHER APPROPRIATE RELIEF.

JASDIP KAUR BOYAL, individually and dba FOOD KING & LIQUOR; (1576 N. First St. Fresno, CA 93703),

) ) ) ) ) ) ) ) ) ) ) Defendant. ) ) )

) THE PEOPLE OF THE STATE OF CALIFORNIA, by and through LISA A.

SMITTCAMP, District Attorney of Fresno County, California, allege as follows:

1. Lisa A. Smittcamp, District Attorney of Fresno County, California, acting to protect the public from fraud, deception, and misleading, unlawful, unfair and fraudulent business practices, brings this action in the name of the People of the State of California.

2. The District Attorney’s authority to bring this action derives from

common law and from statute including, but not limited to, Business and Professions

O 0 1 N

terms of the prior injunction is a violation of Business and Professions Code section 17207.

THIRD CAUSE OF ACTION

Injunctive Relief (Business and Professions Code §§ 17203, 17204 and 17205)

1S. Plaintiff hereby incorporates all of paragraphs 1 through 14, inclusive, of this Complaint as though fully set forth at length herein.

16. Plaintiff 1s informed and believes and thereupon alleges that unless enjoined and festrained by order of this Court, said Defendants will continue to engage in the aforementioned described unlawful conduct in derogation of the rights and interests of the general public as consumers and competitors of Defendants.

PRAYER

WHEREFORE, Plairlltiff prays for the following:

1. That, pursuant to the First Cause of Action, this Court assess a Civil penalty in the amount of TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00) for each violation of Business and Professions Code § 17200, according to proof, but in no event less than TWENTY-FIVE THOUSAND DOLLARS ($25,000.00).

2. That pursuant to the Second Cause of Action, this court assess a Civil penalty in the amount of SIX THOUSAND DOLLARS ($6,000.00) for each violation of Business and Professions Code section 17207, according to proof, but in no event less than TWENTY-FIVE THOUSAND DOLLARS ($25,000.00).

3. That, pursuant to the Third Cause of Action, that Defendant, their directors, officers, employees, agents and representatives, and any and all persons who are acting in concert or participating in any manner with them, or any of them, be permanently enjoined and restrained, directly or indirectly, from engaging in the acts of unfair competition as set forth in this complaint.