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1 <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 />5.4 Reimbursement of Costs of Investigation and Enforcement <br />Defendant shall, within twenty-one (21) business days after entry of this Final Judgment, <br />pay NINE HiJNDRED AND FIFTY THOUSAND DOLLARS ($950,000.00) for reimbursement <br />of attonley's fees, costs of investigation, and other costs of enforcement, to the entities identified <br />in, and in accordance with the ternis of, Exhibits D-1 and D-2, attached. <br />5.5 Couv of Payments to Plaintiff s Representatives <br />Defendant shall, at the time of payment, send an electronic confirnlation of any payment <br />made by wire transfer to the People's representative identified in Paragraph 8. <br />6. ENFORCEMENT OF FINAL JUDGMENT AND PENALTIES <br />The People may move this Court for additional relief for any violation of any provision of <br />this Final Judgment, including but not limited to contempt, additional injunctive provisions, or <br />additional penalties consistent with the provisions of this Final Judgment. Except as otherwise set <br />forth herein, nothing in this Final Judgment shall limit any rights of the People to seek any other <br />relief or remedies provided by law, or the rights of Defendant to defend against any request of the <br />People for such other relief or remedies. <br />7. MATTERS COVERED BY THIS FINAL JUDGMENT <br />7.1 This Final Judgment is a final and binding resolution and settlement of all claims, <br />violations or causes of action expressly alleged by the People in the Complaint or claims that <br />could have been asserted within the scope of the allegations set forth in the Complaint ("Covered <br />Matters''), against Defendant and its subsidiaries, affiliates and corporate parents, and each of <br />their affiliates and parents, Rite Aid Facilities and Former Rite Aid Facilities, successors, heirs, <br />assigns, managed medical groups, and their respective officers, directors, partners, employees, <br />agents, representatives, property owners, and facility operators ("Entities Covered by Final <br />Judgment"). The People further covenant not to sue the Entities Covered by Final Judgment for <br />any Covered Matter. Any claim, violation, or cause of action that is not a Covered Matter is a <br />"Reserved Claim." Reserved Claims include, without limitation, any violation that occurs after <br />the Court's entry of this Final Judgment, subject, however, to the terms of this Final Judgment, <br />including without limitation, subparagraph 4.2.b. Nothing herein shall be interpreted to restrict <br />0 <br />STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION