1 DENNIS J. HERRERA, StateBar#l39669 City Attorney , 2 YVONNE R. MERE, State Bar# 173594 Chief of Complex and Affirmative Litigation 3 NATALIE M. ORR, State Bar #290590 JAIME M. HULING DELAYE, State Bar #270784 4 Deputy City Attorneys Fox Plaza 5 1390 Market Street, 6th Floor San Francisco, California 94102-5408 6 Telephone: (415) 554-3849 Facsimile: (415) 437-4644 7 E-Mail:
[email protected] 8 Attorneys for Plaintiff PEOPLE OF THE STATE OF CALIFORNIA, 9 acting by and through DENNIS J. HERRERA AS CITY ATTORNEY OF SAN FRANCISCO 10 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF SAN FRANCISCO 13 UNLIMITED JURISDICTION 14 PEOPLE OF THE STATE OF CALIFORNIA, case ~GC-18-5638 0 3 acting by and through DENNIS J. HERRERA 15 AS CITY ATTORNEY OF SAN FRANCISCO, COMPLAINT FOR INJUNCTIVE RELIEF 16 AND CIVIL PENALTIES FOR VIOLATIONS Plaintiff, OF BUSINESS AND PROFESSIONS CODE 17 SECTION 17200 vs. 18 TURO INC., and DOES 1-100, inclusive, 19 Defendants. 20 21 22 The PEOPLE OF THE STATE OF CALIFORNIA, by and through San Francisco City 23 Attorney DENNIS J. HERRERA ("the People"), file this Complaint against Defendants TURO INC. 24 and DOES ONE through ONE HUNDRED (collectively, "Turo"). The People allege as follows: 25 INTRODUCTION 26 1. This action arises out of Turo' s unlawful and unfair operation of a rental car business at 27 San Francisco International Airport ("SFO" or "the Airport") without a valid permit, in direct violation 28 of SFO's Rules and Regulations, the California Vehicle Code, and the California Penal Code.