27.  The Pennsylvania Legislature has authorized the City of Philadelphia to impose a  fee of $300.00 per day for each offense under the Philadelphia Code to “[a]ny person who violates  any provision of [the] code or regulations adopted thereunder; or who fails to comply with any  order issued pursuant to any Section thereof; or who erects, constructs, installs, removes, alters, or  repairs a structure, equipment or system in violation of the approved construction documents or  directive of the code official or of a permit or certificate issued under the provisions of [the] code  or the technical codes.”  Philadelphia Administrative Code, Section A-601.   28.  Section 1-109(1) of the Philadelphia Code states that “[u]nless otherwise provided,  the penalty for violation of any provision of the Code or any regulation adopted under it is a fine  not exceeding three hundred dollars ($300) for each offense.  Each day the violation continues is  a separate offense.”  Philadelphia Code, Section 1-109(1).   30.  Section 1-109(3) of the Philadelphia Code states:   For violations that are designated in this Code as "Class III"  offenses, the maximum fine shall be as follows:  (a)   for any violation committed between January 1, 2005 and  December 31, 2005, seven hundred dollars ($700) for each  violation;   (b)   for any violation committed between January 1, 2006 and  December 31, 2006, one thousand one hundred dollars ($1,100) for  each violation;  (c)   for any violation committed between January 1, 2007 and  December 31, 2007, one thousand five hundred dollars ($1,500) for  each violation;  (d)   for any violation committed between January 1, 2008 and  December 31, 2008, one thousand nine hundred dollars ($1,900) for  each violation; and   (e)   for any violation committed on January 1, 2009 or thereafter,  two thousand dollars ($2,000) for each violation.  Philadelphia Code, Section 1-109(3).   31.  On December 20, 2017, the Philadelphia Department of Licenses and Inspections  began issuing notices to Tunskai that its property was in violation of Title 4 of the Philadelphia  Administrative Code, Section A-601.   32.  Pursuant to Philadelphia Code, Section 1-109, L&I fined Tunskai $7,200 per day.    33.  Plaintiff was cited and ordered to pay a total of $2,045,100.    II.  7.  Tunskai bring this class action on behalf of itself and as a class action under Federal  Rule of Civil Procedure 23 on behalf of the following Classes:   I.  VIOLATION NOTICES   VIOLATION OF THE RIGHT UNDER THE FOURTEENTH AMENDMENT  OF THE UNITED STATES CONSTITUTION TO DUE PROCESS   (As Against All Defendants on behalf of the Class)  117.  Plaintiff repeats and re-alleges each and every allegation contained above as though  fully set forth herein.  118.  The Fourteenth Amendment of the United States Constitution, section 1, prohibits  states from depriving any person of life, liberty, or property, without due process of law.    119.  The Defendants’ excessive fines scheme and their enforcement, as well as the  execution proceedings that result from the same, as alleged above, have deprived Plaintiff and the  Class Members of their property in violation of due process, resulting in a wide reach into their  personal and real property.   120.  As a direct result of such violation of due process, Plaintiff and the Class Members  have been damaged.  121.  The Plaintiff and the Class Members are entitled to the recovery of damages, and  appropriate injunctive and declaratory relief, as alleged herein. 