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1 attorney fees; 2 FOURTH CAUSE OF ACTION 3 12. A declaration of the Court that the Defendants violated Government Code 4 §3500, et seq., and that Plaintiffs are entitled to the full relief afforded under 5 Government Code §3500, et seq., including a make whole remedy; 6 13. The granting of appropriate injunctive or other extraordinary relief to 7 remedy the violation and to prevent future violations of a like or similar nature, including, 8 but not limited to, the granting of a temporary restraining order, preliminary injunction, or 9 permanent injunction prohibiting Defendants, and each of them, and their agents, 10 representatives, employees, servants and/or investigators from refusing reasonable 11 requests for information necessary for the POA to represent it members and/or 12 necessary for the members to be represented by the POA. 13 14. That this court issues a temporary restraining order, preliminary and/or 14 permanent injunction enjoining and restraining Defendants, and each of them, and their 15 agents, representatives, employees, servants and/or investigators from interfering 16 and/or restraining the Plaintiffs' right to be represented and/or provide representation. ; 17 15. Awarding of all ancillary relief, including statutory penalties, damages and 18 attorney fees; 19 ALL CAUSES OF ACTION 20 16. That, to the extent declaratory relief is granted in this case, the Court find 21 that Defendants violated Plaintiffs' rights as afforded under Penal Code 22 §832, et seq.; 23 17. For all relief afforded under Government Code §3500, et seq., including, 24 but not limited to that requested herein; 25 18. That Defendants takes nothing by virtue of this action; 26 19. Statutory attorney fees as permitted by law; 27 20. For cost of suit and attorneys fees incurred herein; and 28 21. For such other and further relief as the Court may deem just and proper 19 COMPLAINT