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• ? y i gat:ainahie or a ...ork plan is no longer applicable rhe granting of ar% •ugh <br /> lr �� r,,t E ciirri <br /> 2 or ariendment shall not`lse unrcasonably,,kkithheld <br /> 3 5 Nothing contained herein shall be construed to z3ai%c the rightsof ether Defendan' <br /> 4 or the AGENCY to seek anti available admirustrative interpretation. or administratne or ludicia. i <br /> 5 rex to}+ iii ti`te resolution of azy dispute regarding any action required or ordered b% the -+GFS( � <br /> i <br /> 6 prior to applying to this Court for relief <br /> 7 DISUP TE 12ESO—LU110r <br /> g 6 lin the event that one of the Defendants is unable to reach an agreement with :he <br /> 9 AGENCY regarding any assessment and/or corrective action Issue, mther the Defendant, the <br /> 10 AGENCY, or CBE may request a mcehng between the legal counsel who regularly represents the <br /> i <br /> 1 l AGENCY and Defcndant(s)' designated corporate counsel If the pages are unable to resolve the <br /> 12 dispute,the AGENCY or CBE may proceed to enforce any alleged violations in the manner prodded <br /> 13 form paragraph 7 ofthis Injunction Until further notice to the AGENCY or CBE , Defendants' <br /> 14 designated corporate counsel shall be ]amts L Michalak, Senior Litigation Counsel, F-qui-�a <br /> 15 Services, LLC, 1 Shell Plaza— 1142,P O Box 4254, Houston,Texas, 77002 <br /> 16 7 Prior to an AGENCY instituting, any proceedings to enforce the terms of this <br /> 17 injunction by the filing Ora contempt citation in this action,the AGENCY or their legal counsel shall <br /> 18 provide %ATitten notice to Defendant(s) and their designated corpomte counsel of the proposed <br /> 19 proceedings and the!oasis therefor Prior to CSE Instituting any proceedings to enforce the terms <br /> 20 of this Injunction by the filing of a contempt citation in this action,CBE or their legal counsel shall <br /> 21 provide.written notice to any AGENCY that has authonty over the SM and to the Defcndant(s)and <br /> 22 their designated corporate counsel.of the proposed proceedings and the basis therefor Upon receipt <br /> 23 of such written notice, from either an AGENCY or CBE. Defendant(s) shall be provided the <br /> 24 opportunity to make a good faith effort within the next sixty(60)days to <br /> 25 (a) Satisfy either the AGENCY or CBE and their legal counsel that this Injunction has <br /> 26 not been violated, or <br /> 27 <br /> 28 <br /> Drl6(M IPROpOSEDI STrpU ATFD L-4jUNCi7ON.Page 4 <br />