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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />above. Any penalties or other relief sought by Plaintiff for such violations or alleged violations shall <br />be sought by noticed motion. Plaintiff shall notify Defendant in writing of such alleged violations <br />and shall meet and confer with Defendant within twenty (20) business days of such written notice <br />prior to filing any such motion. The Parties shall negotiate in good faith in an effort to resolve any <br />further penalty assessments or other relief pursuant to this paragraph without judicial inteivention. <br />Defendant reserves all defenses in law and equity. <br />8. If Defendant does not violate the specific injunctive provisions described in paragraphs 6 a <br />and b for the entire three (3) year period after the judgment is entered, the stayed penalty shall be <br />suspended permanently. <br />9. The Plaintiff may move this Court to enjoin any violation of any provision of this <br />Injunction, and to award appropriate relief, including but not limited to contempt and additional <br />penalties. Nothing in this Injunction shall limit any rights of the Plaintiff to seek any other relief or <br />criminal or civil remedies provided by law. <br />10. Defendant shall additionally pay to Plaintiff the sum of ONE THOUSAND FOUR <br />HUNDRED DOLLARS ($1,400.00) as partial recovery of the cost of investigation and suit incurred <br />by the SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DEPARTMENT. Said payment <br />shall be due and payable to the aforementioned agency, and shall be delivered to the San Joaquin <br />County Office of the District Attorney, Environmental Prosecutions Unit, on or before FEBRUARY <br />1, 2013. <br />11. Defendant shall additionally pay to Plaintiff the sum of NINE HUNDRED DOLLARS <br />($900.00) as partial recovery of the cost of investigation and suit incurred by the San Joaquin County <br />Office of the District Attorney. Said payment shall be due and payable to the aforementioned <br />agency, and shall be delivered to the San Joaquin County Office of the District Attorney, <br />Environmental Prosecutions Unit, on or before MAY 1, 2013. <br />12. Defendant is responsible for the uniform fee for filing the first paper in a civil action or <br />proceeding in the Superior Court. The amount of the filing fee is FOUR HUNDRED THIRTY-FIVE <br />DOLLARS ($435.00). Said payment shall be made payable to the SAN JOAQUIN COUNTY <br />SUPERIOR COURT and delivered to the San Joaquin County Office of the District Attorney, <br />-4- <br />PERMANENT INJUNCTION AND FINAL JUDGMENT PURSUANT TO STIPULATION <br />