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A 1 consuming, complex, and would generate extensive costs and involve a significant delay is 2 obtaining any resolution. This Court's approval of the proposed Final Judgment woull 3 eliminate these uncertainties, delays and risks by assessing a set penalty amount, providing fo 4 partial reimbursement' of the People's costs of investigation and enforcement, providing fund; 5 for programs with statewide benefits, would require K MART to maintain and enhance it: 6 environmental compliance program, and impose injunctive responsibilities upon K MARL 7 related to compliance with statutory environmental protection schemes to protect the public and 8 the environment. 9 III. Notice to District Attorneys and Local Regulatory Entities 10 Within two business days of the filing of the Complaint and this Motion, the People will 1I provide notice of the pending action and request for approval of the Final Judgment to the 12 District Attorney Offices with K MART stores in their jurisdiction and to regulatory agencies, 13 referred to as Certified Unified Program Agencies (CUPAs), that have K MART stores in their 14 jurisdictions. See Declaration of David J- Irey filed and served herewith. 15 CONCLUSION 16 For the foregoing reasons, the People respectfully request that the Court approve and 17 enter the Final Judgment based upon a finding that the proposed Final Judgment is fair and 18 reasonable and that entry of the proposed Final Judgment would be in furtherance of the best 19 interests of the People of the State of California and the environment of the State of California. 20 Respectfully submitted, 21 EDMUND G. BROWN JR., Attorney General 22 State of California 23 DATED' Zp� B � y 24 M G TA PADILLA Supe ising Deputy Attorney General 25 Attorneys for Plaintiff 26 27 28 -9- MEMORANDUM OF POINTS AND AUTHORITIES