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i I the,cork described in subparagraph 4.6.a. above.Nothing herein ahal l prevent the People!loin 2 pursuing a,pprol)ritite onforceni$nt oft:his Final Judgment regarding the reverse distrlbutim of 3 over-the-coun.wr nogirescription pharmaceuticals for acts or omissions in violation of applicable 4 law ocuorring on or after ninety(90)days following receipt by Defendant oI l Titten notice as 5 provided by Paragraph 9 of the P'eople's intent to do so. The Parties shall attempt to resolve any 6 such dispute by means of good ia'itli informal negotiations. 7 4.7. Safety Recalls - 8 4.7.a. Begiiming on the Effective Date and continuing until the five(5) year 9 anniversary thereof, Deferidaut slxa.11 work with or continue worldng with appropriatE 10 stakeholders from business and ,goverrunant,including the U.S. Environmontal Protoction 1 I Agency,the U.S. Food and Drug Adin'EnisYration,the California Dcpamnont of Public I-lcaltli an 12 DTSC, either diroetly or tln•ouglt ti ade associations or informal coalitions of interested parties, 13 undertaking to promote regulatory refonn regarding the proper management of products subject 14 to a"Riecall,"as define-! in Paragraph -3,that also may be hazardous waste or medical waste 15 pursuant to the Hazardous Waste Control Law or the Modica!W6ste Man gement Act. Such I16 work may include coi)rdinatlon and communication with national retail trade associations. A 17 descrll)tion of progress on such wodc shat) be included in the Annual Status Reports required.by 1.8 Paragraph 24 below. 19 4,7.b. During thz term.of this Final Judgment,the People may pursue a violation 20 of this l+irml Judgn-ient regarding ilia proper nianagetnent of products subject to a Recall that alba 21 v4y be hazardous waste or medical wfiste under the Hazardous Waste Control Law or the 22 Medical Waste Management Act only if Defendant has failed to demonstrate reasonable i23 diligence in performing the work described in subparagraphi 4.7.a above, Nothing herein shall 24 pt evtint the People from pursuing appi:apriate enforcement of this Ficial.Judgment.regarding ilia 25 proper mwwgetneni of products subject to a Recall that also may be hazardous wastes or medical 26 wasies under the Hamrdous Waste Control Law or the Medical Waste Managment Act for acts i 27 or omissions.in violation of upplicable law occurring on or after ninety(90)days following i 29 receipt by Defendant of written lwtice as provided by Peragreph,9.of the People's intent to do so. I 14 l STIPULATION FOR ENTRY OF FINAL JUDGMENT/IND PERMANENTINJUNCTION I I ' I