Prayer of Complaint
in Case #
"1.) The Property and structures located at 501-695
"2.) The Court declare that the property is in a condition that substantially endangers the health and safety of the residents and the general public;
"3.) Defendants be ordered to vacate the Property and all parts thereof and be enjoined and restrained from renting, leasing, occupying or otherwise using the Property or any part thereof while the conditions described in this Complaint, or any of them, exist and until the property and any structures on the property and all parts thereof have been repaired and restored to conform to law." (p. 12, para. # 3)
"4.) Defendants be ordered to cause the Property and any structures on the Property and all parts thereof to conform to law, Plaintiff's shall in addition to any other remedy provided by law, be authorized to enter upon such premises, remove all persons and personal property situated therein and store such personal property, cause the property, or any portion thereof, to be vacated and barricaded, boarded up, or otherwise secured against use or occupancy pending the repair and correction of all conditions ordered to be corrected, and cause the property, or any portion thereof, to be repaired, so as to render the same safe and in compliance with all applicable law and ordinances;
"5.) Plaintiff's be authorized to obtain the appointment of a receiver to manage the property and abate the violations;
"6.) Plaintiff's shall have a lien upon the Property in the amount expended pursuant to authority and to have judgment in that amount against Defendants, their successors and assigns;
"7.) Defendants be ordered to pay civil penalties of $1,000 for each day any violation of the San Francisco Housing Code was committed or permitted to continue pursuant to San Francisco Housing Code Section 204(c)(2);
"8.) Defendants be declared to have engaged in unfair and unlawful Business acts and practices in violation of Business and Professions Code Sections 17200-17210;
"9.) Defendants, and each of them, inclusive, be enjoined from spending, transferring, encumbering, or removing from California any money received from the Property or in payment for the unfair and unlawful acts alleged in the Complaint;
"10.) Pursuant to Business and Professions Code Section 17203, Defendants be ordered to disgorge all profits obtained through their unfair and unlawful business practices in violation of Business and Professions Code Sections 17200-17210;
"11.) Pursuant to Business and Professions Code Section 17206, Defendants be ordered to pay a civil penalty of $2,500 each for every act of unfair and unlawful competition in violation of Civil Code Section 17200;
"12.) Defendants be ordered to pay an additional civil penalty of $2,500 each for every unfair act that harmed an elderly or disabled person pursuant to Business and Professions Code Section 17206.1;
"13.) Pursuant to Business and Professions Code Section 17203, that the Court order restitution of all money or property acquired by Defendants as a result of the unlawful business practices to former and present occupants of the Property during all times relevant to the Complaint;
"14.) The lawful tenants of the Property be entitled to relocation assistance, pursuant to Health and Safety Code 17980.7(d)(3);
"15.) Plaintiffs be awarded from Defendants or their successors, heirs, or assigns, all costs of suit, including attorney's fees, costs of investigation, discovery, enforcement and prosecution, as provided by the State Housing Law, Health and Safety Code Section 17980.7(d)(1);
"16.) Plaintiffs be awarded their costs incurred herein pursuant to Code of Civil Procedure Section 1032;
"17.) Recordation of an abstract of judgment in this case constitute a prior lien over any lien that may be held on the Property by any Defendants to this action; and
"18.) Plaintiffs have such further and other relief as the Court deems just, including an award of attorneys fees and costs as permitted by statute."