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I 13.aaa., 13.ff£, 13.111., or 13.000. of the Complaint. If, after the period set by Plaintiff for 2 Defendants to remedy the violation has passed (or at any time in Plaintiff's discretion if no period 3 for Defendants' remedy is allowed), Plaintiff believes that Defendants remain deficient in 4 compliance with the requirements contained in the provisions of Paragraph 6 of this Stipulation 5 and the Final Judgment entered in this action, Plaintiff may (1) move this Court for appropriate 6 relief, including but not limited to seeking sanctions, contempt or other relief as provided by law 7 for violation of the Final Judgment, or (2) commence a separate enforcement action against 8 Defendants for the alleged violation(s) of the statutes and/or regulations set forth in Paragraph 6 9 of the Final Judgment entered in this action. A violation by Defendants of the provisions imposed 10 by Paragraph 6 of the Final Judgment entered in this action shall be considered a claim separate 11 and in addition to any claim that may be made by Plaintiff, CUPAs, or any other prosecution or 12 enforcement agency for a violation by Defendants of the underlying statutory or regulatory 13 requirements, which may be enforced separately in another proceeding. For potential violations 14 by Defendants of the provisions imposed by Paragraph 6 of the Final Judgment entered in this 15 action,the Office of the Attorney General, when acting in its independent capacity on behalf of 16 the People of the State of California, when electing to pursue a future enforcement action will 17 consider whether it is appropriate to seek monetary relief against Defendants if an amount of 18 penalties has been previously awarded to a CUPA or other enforcement agency for the same 19 underlying statutory or regulatory violation having to do with the same course of conduct. In the 20 event that the People elect to pursue the imposition of injunctive relief for a violation of 21 Paragraph 6 of the Final Judgment entered in this action in addition to an award of fines or 22 penalties to the People, a CUPA, or any other enforcement agency,Defendants reserve all 23 applicable equitable defenses that Defendants may have to the imposition of such an award. 24 (e) Except as provided in Paragraphs 2, 11, and 19-21 below,nothing in this Final 25 Judgment shall restrict or condition the ability of the People, a CUPA, or any other enforcement 26 agency to separately administer, to initiate a separate new enforcement action or take immediate 27 action to protect the public health and/or environment or to enforce state laws or regulations, 28 County Codes, or the provisions of any order or permit issued by any other agency or entity. 13 Stipulation for Entry of Final Judgment and Permanent Injunction