This decision affirms denial of defendant’s motion to disqualify the private attorneys whom San Diego hired on contingency fee contracts to prosecute this suit for civil penalties under B&P Code 17200. The contingency fee contracts specified that the City Attorney retained ultimate control over the litigation or its settlement, and the contracts contained other clauses required under County of Santa Clara v. Superior Court (2010) 50 Cal.4th 35. Civil penalties are not sufficient penal in nature as to require any greater protection or prosecutor neutrality. The contracts also didn’t violate B&P Code 17206 by providing that the City would escrow some of the civil penalties it received in order to pay contingency fees to the private attorneys.