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0 0 <br /> 1 a. To defendant B&G Group, Inc.,a California corporation care of its counsel: <br /> 2 Michael M.Ching <br /> Cannata Ching&O'Toole LLP <br /> 3 100 Pine Street,Ste.350 <br /> San Francisco,CA 94111 <br /> 4 <br /> b. To San Joaquin County Office of the District Attorney,care of: <br /> 5 <br /> D.Scott McDonald <br /> 6 Deputy District Attorney <br /> Environmental Prosecutions Unit <br /> 7 222 E. Weber Avenue, Room 202 <br /> Stockton,CA 95202 <br /> 8 <br /> 9 22. This Agreement may be signed in counterparts,each of which,when executed shall <br /> 10 constitute an original, but such counterparts collectively,in their entirety,shall together,be <br /> I 1 considered one and the same Consent Agreement. Facsimile or PDF signatures shalt be treated as <br /> 12 original signatures for purposes of this Consent Agreement. <br /> 13 23. The Court shall retain continuing jurisdiction under California Code of Civil Procedure <br /> 14 section 664.6 to enforce the terms of this Consent Agreement and to address any other matters <br /> 15 arising out of or regarding this Consent Agreement. The Parties shall meet and confer prior to the <br /> 16 filing of any motion,action,or lawsuit relating to this Consent Agreement and shall negotiate in <br /> 17 good faith in an effort to resolve any dispute without judicial intervention. This Consent Agreement <br /> 18 shall go into effect immediately upon entry hereof. Entry is authorized immediately upon filing. <br /> 19 24. All Defendants covenant not to sue or pursue any civil or administrative claims against <br /> 20 Plaintiff or agencies of the State of California,any counties of the State of California or any <br /> 21 Certified Unified Program Agency, Participating Agency or Unified Program Agency as those terms <br /> 22 are defined pursuant to Health and Safety Code Section 25281(d)(1)(2)and(3), including but not <br /> 23 limited to,the San Joaquin County Environmental Health Department,or their officers,employees, <br /> 24 representatives,agents or attorneys arising out of or related to any matter alleged to have occurred <br /> 25 prior to the entry of this Consent Agreement,except for the purpose of enforcing Plaintiffs <br /> 26 obligations under this Consent Agreement. Nothing in this Consent Agreement shall operate to <br /> 27 waive any right or ability to pursue any claim for relief or cause of action that may arise after the date <br /> 28 of the Court's entry of this Order. <br /> -8- <br /> CONSENT AGREEMENT AND STIPULATION FOR ENTRY OF FINAL JUDGMENT AND ORDER(PROPOSED) <br />