Preview
1 Sebastian M. Medvei (SBN 285604)
MEDVEI LAW GROUP, APC
2 655 N. Central Avenue, Ste 1700
Glendale, CA 91203
3 Telephone: (213) 984-4013
Email: smedvei.irdcmatters@medveilaw.com
4
Attorney for Plaintiff IMMIGRANT RIGHTS
5 DEFENSE COUNCIL, LLC
6
7 SUPERIOR COURT FOR THE STATE OF CALIFORNIA
8
FOR THE COUNTY OF RIVERSIDE, RIVERSIDE HISTORIC COURTHOUSE
9
10 IMMIGRANT RIGHTS DEFENSE Case No.:
11 COUNCIL, LLC, a California Limited COMPLAINT FOR INJUNCTIVE
RELIEF:
12 Liability Company, 1. Violation of the Immigration Consultant Act
13 Plaintiff,
14 vs.
15 MONIQUE VIGIL, an individual; ROSALBA
16 VIGIL, an individual; SERVICIO LATINO,
17 INC, a California Corporation; DOES 1
18 THROUGH 100, inclusive,
19 Defendants.
20
21 Plaintiff alleges as follows:
22
23 PARTIES
24 1. Plaintiff IMMIGRANT RIGHTS DEFENSE COUNCIL, LLC ("Plaintiff") is a
25 limited liability company duly organized under the laws of the State of California. Plaintiff is a
26 non-governmental organization (NGO) bringing actions on behalf of the people of the State of
27 California under the Immigration Consultants Act (ICA) to shut down illegally operated
28 immigration consultant businesses in the State of California.
1
Complaint for Injunctive Relief
1 2. Plaintiff is informed and believes, and thereon alleges, that Defendants
2 MONIQUE VIGIL ("Defendant Monique Vigil") and ROSALBA VIGIL (“Defendant Rosalba
3 Vigil”) are individuals residing in Riverside County. Plaintiff is informed and believes that
4 Defendants Monique Vigil and Rosalba Vigil operate under the fictitious name (dba) of
5 LATINO SERVICE” and “SERVICIO LATINO, INC” located at 1299 Columbia Avenue, Ste
6 E4, Riverside, CA 92507.
7 3. Plaintiff is informed and believes that Defendant “SERVICIO LATINO, INC”
8 (“Defendant Corp”) is a corporation duly incorporated under the laws of the State of California
9 with its principal place of business and headquarters in Riverside, California. On information and
10 belief, the Defendant Corp was formed solely as a vehicle for Defendants Monique Vigil and
11 Rosalba Vigil to avoid liability for their personal conduct such that Defendant Corp is the alter
12 ego of Defendants Monique Vigil and Rosalba Vigil. Defendant Corp is not a law corporation.
13 4. Plaintiff is unaware of the true names and capacities of defendants sued herein as
14 DOES 1 THROUGH 100, inclusive, and therefore sue these defendants by such fictitious names
15 pursuant to Code of Civil Procedure 474. Plaintiff will amend the complaint to show the true
16 names and capacities of such DOES when they have been ascertained. Plaintiff is informed and
17 believes, and thereon alleges, that each of the fictitiously named defendants is responsible in
18 some manner for the actions and occurrences herein alleged, and that plaintiffs’ damages as
19 herein alleged were proximately caused by their acts.
20 5. Plaintiff is informed and believes, and thereon alleges, that Defendants Monique
21 Vigil, Rosalba Vigil and “SERVICIO LATINO, INC” and DOES 1 THROUGH 100 (hereinafter
22 collectively referred to as “Defendants”), each acted in concert with, and was the agent,
23 employee, contractor, partner, principal, servant, and/or representative of, each of the other
24 Defendants, and in doing the acts hereinafter alleged was acting in concert and within the course
25 and scope of its authority as an agent, servant, officer, employee and/or representative, with the
26 permission and consent of the other Defendants. Plaintiff is informed and believes, and thereon
27 also alleges, that Defendants are each liable for the acts of each of the other Defendants insofar
28
2
Complaint for Injunctive Relief
1 as any one of the Defendants is the principal and/or agent, employee, contractor, partner, servant,
2 and/or representative of the other Defendants.
3 6. Plaintiff is informed and believes, and thereon alleges, that Defendants each
4 ratified and/or authorized the acts of each of the other Defendants insofar as any one of the
5 Defendants is the principal and/or agent, employee, contractor, partner, servant, and/or
6 representative of the other Defendants.
7 7. Plaintiff is informed and believes, and thereon alleges, that Defendants have
8 engaged in a conspiracy, common enterprise, and common course of conduct, the purpose of
9 which is and was to engage in the violations of law alleged in this Complaint. This conspiracy,
10 common enterprise, and common course of conduct continues to the present.
11
12 GENERAL ALLEGATIONS
13 8. Defendants are in the business of acting as immigration consultants.
14 9. The Immigration Consultant Act (ICA), beginning at Business and Professions
15 Code Section 22440, et seq., regulates the conduct of persons engaging in the business of an
16 immigration consultant.
17 10. Specifically, the ICA, without limitation, requires the following:
18 a. That all immigration consultants practice in conformity with the ICA. Bus. &
19 Prof. Code § 22440.
20 b. That immigration consultants only engage in completing immigration forms,
21 without advising a person as to their answers on those forms. Bus. & Prof Code § 22441(a)(1).
22 c. That immigration consultants only engage in translating a person's answers to
23 questions posed on immigration forms. Bus. & Prof Code § 22441(a)(2).
24 d. That immigration consultants only engage in securing for a person supporting
25 documents, such as birth certificates, which may be necessary to complete immigration forms.
26 Bus. & Prof Code § 22441(a)(3).
27 ///
28 ///
3
Complaint for Injunctive Relief
1 e. That immigrations consultants only engage in submitting completed forms on a
2 person's behalf and at their request to the United States Citizenship and Immigration Services.
3 Bus. & Prof Code § 22441(a)(4).
4 f. That immigrations consultants only engage in making referrals to persons who
5 could undertake legal representation activities for a person in an immigration matter. Bus. & Prof
6 Code § 22441(a)(5).
7 g. That doing anything outside of the tasks provided by Business and Professions
8 Code Sections 22441(a)(1)-(5) is a violation of the ICA. Bus. & Prof Code § 22441(d).
9 h. That all immigration consultants pass a background check conducted by the
10 Secretary of State. Bus. & Prof Code § 22441.1(a).
11 i. That all immigration consultants provide a written, itemized contract, the contents
12 of which shall be prescribed by the Department of Consumer Affairs in regulations, Bus. & Prof
13 Code § 22442(a), setting forth each individual task to be performed, in English and the client's
14 native language. Bus. & Prof Code § 22442.
15 j. That all immigrations consultants shall provide a typed or computer generated,
16 signed receipt to a client for each payment made by that client, Bus. & Prof Code § 22442.1(a),
17 and render an accounting for the services rendered and payments made to the client every two
18 months with a written translation in the client's native language. Bus. & Prof Code § 22442.1(b).
19 k. That all immigration consultants shall conspicuously display in their office a
20 notice in English and the native language of the consultant's clientele, setting forth various
21 information, including bonding information and a statement that the immigration consultant is
22 not an attorney. Bus. & Prof Code § 22442.2(a).
23 l. That all immigration consultants shall provide, prior to providing services to a
24 client, a written disclosure in the native language of the client, setting forth various information,
25 including bonding information and the consultant's agent for service of process. Bus. & Prof
26 Code § 22442.2(b).
27 ///
28 ///
4
Complaint for Injunctive Relief
1 m. That all advertisements of the immigration consultant include a clear and
2 conspicuous statement that the immigration consultant is not an attorney. Bus. & Prof Code §
3 22442.2(c).
4 n. That an immigration consultant shall not translate from English into another
5 language any words or titles that might imply that the consultant is an attorney, including,
6 without limitation, the words "notary," "licensed," and "attorney." Bus. & Prof Code §
7 22442.3(a).
8 o. That an immigration consultant submit to the Department of Justice fingerprint
9 images and related information for purposes of a criminal background check. Bus. & Prof Code
10 § 22442.4(a).
11 p. That an immigration consultant who provides immigration reform act services
12 establish and deposit any funds received from a client into a client trust account. Bus. & Prof
13 Code § 22442.5(a).
14 q. That an immigration consultant may not demand or accept advance payment from
15 persons related to certain immigration reform act services or in connection with certain other
16 services as set forth in the ICA. Bus. & Prof Code § 22442.6.
17 r. That an immigration consultant provide copies of all documents prepared, and
18 maintain copies of documents prepared for not less than three years. Bus. & Prof Code § 22443.
19 s. That an immigration consultant maintain a bond of $100,000 executed by a
20 corporate surety admitted to do business in California. Bus. & Prof Code § 22443.1.
21 t. That an immigration consultant may not advertise themselves as a consultant
22 without maintaining the above-mentioned bond. Bus. & Prof Code § 22443.3.
23 u. That an immigration consultant may not make false or misleading statements to a
24 client while providing services to the client. Bus. & Prof Code § 22444(a).
25 v. That an immigration consultant may not make any guarantee or promise to a
26 client, unless it is in writing and supported by some basis in fact. Bus. & Prof Code § 22444(b).
27 w. That an immigration consultant may not make any statement that the consultant
28 can obtain special favors from government employees. Bus. & Prof Code § 22444(c).
5
Complaint for Injunctive Relief
1 x. That an immigration consultant may not charge a client a fee for referral of the
2 client to another for services which the immigration consultant cannot or will not provide to the
3 client. Bus. & Prof Code § 22444(d).
4 11. Any party, who upon information and belief, believes that a person or entity has
5 violated the ICA may bring an action for injunctive relief on behalf of the general public. Bus. &
6 Prof Code § 22446.5(b).
7
8 FIRST CAUSE OF ACTION
9 Plaintiff against all Defendants for Violation of the Immigration Consultant Act
10 (California Business and Professions Code section 22440 et seq.)
11 12. Plaintiff incorporate by reference the allegations of paragraphs 1 through 10
12 above, as if fully set forth herein.
13 13. Defendants are engaged in the business of an immigration consultant.
14 14. Defendants, in addition to the conduct set forth above, have engaged in the
15 following conduct:
16 a. Not practicing in conformity with the ICA.
17 b. Advising clients how to answer on immigration forms.
18 c. Holding out as an attorney to the public.
19 d. Providing legal advice.
20 e. Failing to submit a background check to the Secretary of State.
21 f. Failing to provide a written contract meeting the requirements of the ICA.
22 g. Failing to provide receipts and accountings in conformity with the ICA.
23 h. Failing to conspicuously display the notices required under the ICA.
24 i. Failing to provide the written disclosures required under the ICA.
25 j. Failing to conspicuously state in advertisements that Defendants are not attorneys.
26 k. Translating from English to another language the words proscribed by the ICA,
27 including, without limitation, the words "notary," "licensed," and "attorney."
28 ///
6
Complaint for Injunctive Relief
1 l. Failing to submit to the Department of Justice fingerprint images for the purposes
2 of a background check.
3 m. Failing to maintain a client trust account as required under the ICA.
4 n. Demanding advance payment for certain services as proscribed by the ICA.
5 o. Failing to maintain a bond of $100,000.
6 p. Advertising as an immigration consultant without maintaining the above-
7 mentioned bond.
8 q. Making false and misleading statements to a client while providing services to the
9 client.
10 r. Making oral guarantees and promises to a client, and/or written guarantees and
11 promises not based in any supportable fact.
12 s. Making a statement that Defendants can secure special favors from government
13 officials for clients.
14 t. Charging a fee for referrals.
15 15. As such, Plaintiff seeks a judgment permanently enjoining Defendants from
16 violating the above-listed provisions of the ICA, and, from engaging in the business of an
17 immigration consultant.
18 16. Pursuant to section 22446.5(a) of the Business and Professions Coode, Plaintiff is
19 entitled to recover its reasonable attorneys' fees and costs in bringing this action.
20
21 PRAYER FOR RELIEF
22 WHEREFORE, Plaintiff prays for judgment against Defendants, as follows:
23 (1) Injunctive relief;
24 (2) For reasonable attorneys’ fees;
25 (3) For costs of suit incurred herein; and,
26 (4) For such other relief the Court deems just and proper.
27
28
7
Complaint for Injunctive Relief
1 Dated May 9, 2022 Respectfully Submitted,
2 MEDVEI LAW GROUP, APC
3
4 By: /s/ Sebastian M. Medvei
5 Sebastian M. Medvei
6
7
Attorney for Plaintiff
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
8
Complaint for Injunctive Relief
Preview
1 Sebastian M. Medvei (SBN 285604) MEDVEI LAW GROUP, APC 2 655 N. Central Avenue, Ste 1700 Glendale, CA 91203 3 Telephone: (213) 984-4013 Email: smedvei.irdcmatters@medveilaw.com 4 Attorney for Plaintiff IMMIGRANT RIGHTS 5 DEFENSE COUNCIL, LLC 6 7 SUPERIOR COURT FOR THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF RIVERSIDE, RIVERSIDE HISTORIC COURTHOUSE 9 10 IMMIGRANT RIGHTS DEFENSE Case No.: 11 COUNCIL, LLC, a California Limited COMPLAINT FOR INJUNCTIVE RELIEF: 12 Liability Company, 1. Violation of the Immigration Consultant Act 13 Plaintiff, 14 vs. 15 MONIQUE VIGIL, an individual; ROSALBA 16 VIGIL, an individual; SERVICIO LATINO, 17 INC, a California Corporation; DOES 1 18 THROUGH 100, inclusive, 19 Defendants. 20 21 Plaintiff alleges as follows: 22 23 PARTIES 24 1. Plaintiff IMMIGRANT RIGHTS DEFENSE COUNCIL, LLC ("Plaintiff") is a 25 limited liability company duly organized under the laws of the State of California. Plaintiff is a 26 non-governmental organization (NGO) bringing actions on behalf of the people of the State of 27 California under the Immigration Consultants Act (ICA) to shut down illegally operated 28 immigration consultant businesses in the State of California. 1 Complaint for Injunctive Relief 1 2. Plaintiff is informed and believes, and thereon alleges, that Defendants 2 MONIQUE VIGIL ("Defendant Monique Vigil") and ROSALBA VIGIL (“Defendant Rosalba 3 Vigil”) are individuals residing in Riverside County. Plaintiff is informed and believes that 4 Defendants Monique Vigil and Rosalba Vigil operate under the fictitious name (dba) of 5 LATINO SERVICE” and “SERVICIO LATINO, INC” located at 1299 Columbia Avenue, Ste 6 E4, Riverside, CA 92507. 7 3. Plaintiff is informed and believes that Defendant “SERVICIO LATINO, INC” 8 (“Defendant Corp”) is a corporation duly incorporated under the laws of the State of California 9 with its principal place of business and headquarters in Riverside, California. On information and 10 belief, the Defendant Corp was formed solely as a vehicle for Defendants Monique Vigil and 11 Rosalba Vigil to avoid liability for their personal conduct such that Defendant Corp is the alter 12 ego of Defendants Monique Vigil and Rosalba Vigil. Defendant Corp is not a law corporation. 13 4. Plaintiff is unaware of the true names and capacities of defendants sued herein as 14 DOES 1 THROUGH 100, inclusive, and therefore sue these defendants by such fictitious names 15 pursuant to Code of Civil Procedure 474. Plaintiff will amend the complaint to show the true 16 names and capacities of such DOES when they have been ascertained. Plaintiff is informed and 17 believes, and thereon alleges, that each of the fictitiously named defendants is responsible in 18 some manner for the actions and occurrences herein alleged, and that plaintiffs’ damages as 19 herein alleged were proximately caused by their acts. 20 5. Plaintiff is informed and believes, and thereon alleges, that Defendants Monique 21 Vigil, Rosalba Vigil and “SERVICIO LATINO, INC” and DOES 1 THROUGH 100 (hereinafter 22 collectively referred to as “Defendants”), each acted in concert with, and was the agent, 23 employee, contractor, partner, principal, servant, and/or representative of, each of the other 24 Defendants, and in doing the acts hereinafter alleged was acting in concert and within the course 25 and scope of its authority as an agent, servant, officer, employee and/or representative, with the 26 permission and consent of the other Defendants. Plaintiff is informed and believes, and thereon 27 also alleges, that Defendants are each liable for the acts of each of the other Defendants insofar 28 2 Complaint for Injunctive Relief 1 as any one of the Defendants is the principal and/or agent, employee, contractor, partner, servant, 2 and/or representative of the other Defendants. 3 6. Plaintiff is informed and believes, and thereon alleges, that Defendants each 4 ratified and/or authorized the acts of each of the other Defendants insofar as any one of the 5 Defendants is the principal and/or agent, employee, contractor, partner, servant, and/or 6 representative of the other Defendants. 7 7. Plaintiff is informed and believes, and thereon alleges, that Defendants have 8 engaged in a conspiracy, common enterprise, and common course of conduct, the purpose of 9 which is and was to engage in the violations of law alleged in this Complaint. This conspiracy, 10 common enterprise, and common course of conduct continues to the present. 11 12 GENERAL ALLEGATIONS 13 8. Defendants are in the business of acting as immigration consultants. 14 9. The Immigration Consultant Act (ICA), beginning at Business and Professions 15 Code Section 22440, et seq., regulates the conduct of persons engaging in the business of an 16 immigration consultant. 17 10. Specifically, the ICA, without limitation, requires the following: 18 a. That all immigration consultants practice in conformity with the ICA. Bus. & 19 Prof. Code § 22440. 20 b. That immigration consultants only engage in completing immigration forms, 21 without advising a person as to their answers on those forms. Bus. & Prof Code § 22441(a)(1). 22 c. That immigration consultants only engage in translating a person's answers to 23 questions posed on immigration forms. Bus. & Prof Code § 22441(a)(2). 24 d. That immigration consultants only engage in securing for a person supporting 25 documents, such as birth certificates, which may be necessary to complete immigration forms. 26 Bus. & Prof Code § 22441(a)(3). 27 /// 28 /// 3 Complaint for Injunctive Relief 1 e. That immigrations consultants only engage in submitting completed forms on a 2 person's behalf and at their request to the United States Citizenship and Immigration Services. 3 Bus. & Prof Code § 22441(a)(4). 4 f. That immigrations consultants only engage in making referrals to persons who 5 could undertake legal representation activities for a person in an immigration matter. Bus. & Prof 6 Code § 22441(a)(5). 7 g. That doing anything outside of the tasks provided by Business and Professions 8 Code Sections 22441(a)(1)-(5) is a violation of the ICA. Bus. & Prof Code § 22441(d). 9 h. That all immigration consultants pass a background check conducted by the 10 Secretary of State. Bus. & Prof Code § 22441.1(a). 11 i. That all immigration consultants provide a written, itemized contract, the contents 12 of which shall be prescribed by the Department of Consumer Affairs in regulations, Bus. & Prof 13 Code § 22442(a), setting forth each individual task to be performed, in English and the client's 14 native language. Bus. & Prof Code § 22442. 15 j. That all immigrations consultants shall provide a typed or computer generated, 16 signed receipt to a client for each payment made by that client, Bus. & Prof Code § 22442.1(a), 17 and render an accounting for the services rendered and payments made to the client every two 18 months with a written translation in the client's native language. Bus. & Prof Code § 22442.1(b). 19 k. That all immigration consultants shall conspicuously display in their office a 20 notice in English and the native language of the consultant's clientele, setting forth various 21 information, including bonding information and a statement that the immigration consultant is 22 not an attorney. Bus. & Prof Code § 22442.2(a). 23 l. That all immigration consultants shall provide, prior to providing services to a 24 client, a written disclosure in the native language of the client, setting forth various information, 25 including bonding information and the consultant's agent for service of process. Bus. & Prof 26 Code § 22442.2(b). 27 /// 28 /// 4 Complaint for Injunctive Relief 1 m. That all advertisements of the immigration consultant include a clear and 2 conspicuous statement that the immigration consultant is not an attorney. Bus. & Prof Code § 3 22442.2(c). 4 n. That an immigration consultant shall not translate from English into another 5 language any words or titles that might imply that the consultant is an attorney, including, 6 without limitation, the words "notary," "licensed," and "attorney." Bus. & Prof Code § 7 22442.3(a). 8 o. That an immigration consultant submit to the Department of Justice fingerprint 9 images and related information for purposes of a criminal background check. Bus. & Prof Code 10 § 22442.4(a). 11 p. That an immigration consultant who provides immigration reform act services 12 establish and deposit any funds received from a client into a client trust account. Bus. & Prof 13 Code § 22442.5(a). 14 q. That an immigration consultant may not demand or accept advance payment from 15 persons related to certain immigration reform act services or in connection with certain other 16 services as set forth in the ICA. Bus. & Prof Code § 22442.6. 17 r. That an immigration consultant provide copies of all documents prepared, and 18 maintain copies of documents prepared for not less than three years. Bus. & Prof Code § 22443. 19 s. That an immigration consultant maintain a bond of $100,000 executed by a 20 corporate surety admitted to do business in California. Bus. & Prof Code § 22443.1. 21 t. That an immigration consultant may not advertise themselves as a consultant 22 without maintaining the above-mentioned bond. Bus. & Prof Code § 22443.3. 23 u. That an immigration consultant may not make false or misleading statements to a 24 client while providing services to the client. Bus. & Prof Code § 22444(a). 25 v. That an immigration consultant may not make any guarantee or promise to a 26 client, unless it is in writing and supported by some basis in fact. Bus. & Prof Code § 22444(b). 27 w. That an immigration consultant may not make any statement that the consultant 28 can obtain special favors from government employees. Bus. & Prof Code § 22444(c). 5 Complaint for Injunctive Relief 1 x. That an immigration consultant may not charge a client a fee for referral of the 2 client to another for services which the immigration consultant cannot or will not provide to the 3 client. Bus. & Prof Code § 22444(d). 4 11. Any party, who upon information and belief, believes that a person or entity has 5 violated the ICA may bring an action for injunctive relief on behalf of the general public. Bus. & 6 Prof Code § 22446.5(b). 7 8 FIRST CAUSE OF ACTION 9 Plaintiff against all Defendants for Violation of the Immigration Consultant Act 10 (California Business and Professions Code section 22440 et seq.) 11 12. Plaintiff incorporate by reference the allegations of paragraphs 1 through 10 12 above, as if fully set forth herein. 13 13. Defendants are engaged in the business of an immigration consultant. 14 14. Defendants, in addition to the conduct set forth above, have engaged in the 15 following conduct: 16 a. Not practicing in conformity with the ICA. 17 b. Advising clients how to answer on immigration forms. 18 c. Holding out as an attorney to the public. 19 d. Providing legal advice. 20 e. Failing to submit a background check to the Secretary of State. 21 f. Failing to provide a written contract meeting the requirements of the ICA. 22 g. Failing to provide receipts and accountings in conformity with the ICA. 23 h. Failing to conspicuously display the notices required under the ICA. 24 i. Failing to provide the written disclosures required under the ICA. 25 j. Failing to conspicuously state in advertisements that Defendants are not attorneys. 26 k. Translating from English to another language the words proscribed by the ICA, 27 including, without limitation, the words "notary," "licensed," and "attorney." 28 /// 6 Complaint for Injunctive Relief 1 l. Failing to submit to the Department of Justice fingerprint images for the purposes 2 of a background check. 3 m. Failing to maintain a client trust account as required under the ICA. 4 n. Demanding advance payment for certain services as proscribed by the ICA. 5 o. Failing to maintain a bond of $100,000. 6 p. Advertising as an immigration consultant without maintaining the above- 7 mentioned bond. 8 q. Making false and misleading statements to a client while providing services to the 9 client. 10 r. Making oral guarantees and promises to a client, and/or written guarantees and 11 promises not based in any supportable fact. 12 s. Making a statement that Defendants can secure special favors from government 13 officials for clients. 14 t. Charging a fee for referrals. 15 15. As such, Plaintiff seeks a judgment permanently enjoining Defendants from 16 violating the above-listed provisions of the ICA, and, from engaging in the business of an 17 immigration consultant. 18 16. Pursuant to section 22446.5(a) of the Business and Professions Coode, Plaintiff is 19 entitled to recover its reasonable attorneys' fees and costs in bringing this action. 20 21 PRAYER FOR RELIEF 22 WHEREFORE, Plaintiff prays for judgment against Defendants, as follows: 23 (1) Injunctive relief; 24 (2) For reasonable attorneys’ fees; 25 (3) For costs of suit incurred herein; and, 26 (4) For such other relief the Court deems just and proper. 27 28 7 Complaint for Injunctive Relief 1 Dated May 9, 2022 Respectfully Submitted, 2 MEDVEI LAW GROUP, APC 3 4 By: /s/ Sebastian M. Medvei 5 Sebastian M. Medvei 6 7 Attorney for Plaintiff 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 8 Complaint for Injunctive Relief