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1 2, I am familiar with and have reviewed the contents of Plaintiff s filings in this matter <br />2 Attached hereto as Exhibit "1" is a true and correct copy of the Stipulation for Entry of <br />3 Final Judgment and Final Judgment ("Final Judgment") in this case. <br />4 3. Within two (2) business days of filing of the Complaint for Injunction, Civil Penalties <br />5 and Other Equitable Relief ("Complaint"), and of the instant motion, and within two (2) <br />6 business days of the lodging of the Final Judgment with the Court, our office will scan <br />7 the Complaint, the Motion and the Final Judgment and serve them electronically to each <br />8 District Attorney's Office in the State of California that has a "Covered Facility" within <br />9 its jurisdiction and that is not part of the prosecution team which negotiated the Final <br />10 Judgment lodged with this Court for approval. <br />11 4. Within two (2) business days of filing of the Complaint and the Motion, and within two <br />12 (2) business days of the lodging of the Final Judgment, my office will scan the <br />13 Complaint, Motion and Final Judgment and forward them electronically to each Certified <br />14 Unified Program Agency (CUPA) in the State of California that has any "Covered <br />15 Facility" within its jurisdiction. <br />16 5. I have made inquiries and determined that there are no pending enforcement matters by <br />17 prosecutors against KMART in the State of California arising from alleged violations of <br />18 Chapter 6.5 or Chapter 6.95, Division 20, of the Health and Safety Code as of this date. I <br />19 have further consulted counsel of record for KMART in this matter, and with corporate <br />20 counsel for KMART, and have been informed that there are no known enforcement <br />21 matters pending elsewhere in the State of California arising from alleged violations of <br />22 Chapter 6.5 or Chapter 6.95, Division 20, of the Health and Safety Code as of this date. <br />23 6. Prior to the court date scheduled for obtaining the Court's signature on the Final <br />24 Judgment, I shall file another Declaration confirming that I have completed the tasks set <br />25 forth above in this Declaration. <br />26 I declare under penalty of perjury under the laws of the State of California that the <br />27 foregoing is true and correct. <br />28 <br />-2- <br />DECLARATION OF DAVID J. IREY RE: NOTIFICATION OF POTENTIALLY INTERESTED PARTIES <br />