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I action for the supplemental environmental compliance measures identified in, and in accordance <br /> 2 with, the terms of Exhibit E, attached hereto and,by this reference, made part of this Stipulation <br /> 3 and the Final Judgment entered in this action. <br /> 4 ENFORCEMENT AND LIABILITY <br /> FOR NONCOMPLIANCE BY DEFENDANTS <br /> 5 <br /> 6 11. The provisions in this Final Judgment will be enforceable only by the Parties hereto. <br /> 7 (a) If Plaintiff believes that Defendants failed to comply with any of the injunctive <br /> 8 relief provisions set forth in Paragraph 7 of this Stipulation and the Final Judgment entered in this <br /> 9 action, Plaintiff may at any time serve a Notice of Deficiency on Defendants pursuant to <br /> 10 Paragraph 16 below that, to the extent available information allows, (1) identifies the specific <br /> 11 instance and dates of non-compliance, (2) identifies proposed action(s)that Defendants might <br /> I2 take to remedy that non-compliance, if the non-compliance is alleged to be ongoing, and <br /> 13 (3)requests that Defendants remedy the non-compliance. If, after a reasonable cure period, as <br /> 14 determined by Plaintiff, Plaintiff believes that Defendants remain deficient in compliance with the <br /> 15 Final Judgment entered in this action, Plaintiff may move this Court to enjoin the actions of <br /> 16 Defendants to prevent any further violation of Paragraph 7 of this Stipulation and of the Final <br /> 17 Judgment, and/or for sanctions, contempt or other relief as provided by law for violation of the <br /> 18 Final Judgment. <br /> 19 (b) If Plaintiff believes that Defendants have failed to comply with any of the <br /> 20 injunctive relief provisions set forth in Paragraph 6 of this Stipulation and the Final Judgment <br /> 21 entered in this action, Plaintiff may at any time serve a Notice of Deficiency on Defendants <br /> 22 pursuant to Paragraph 16 below that, to the extent available information allows, (1) identifies the <br /> 23 specific instance and dates of non-compliance, (2) identifies proposed action(s)that Defendants <br /> 24 might take to remedy that non-compliance, if the non-compliance is alleged to be ongoing, and <br /> 25 (3) requests that Defendants remedy the non-compliance; provided, however, that nothing <br /> 26 contained in the provisions of this Stipulation or the Final Judgment entered in this action shall <br /> 27 require Plaintiff to serve any notice on Defendants for violations of the statutory and/or regulatory <br /> 28 provisions set forth in Paragraph 13.a., 13.u., 13.x., 13.bb., 13,hh., 131k., 13.00., 13.gq., 13.vv., <br /> 12 <br /> Stipulation for Entry of Final Judgment and Permanent Injunction <br />