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j 1 20. PAYMENT OF LITIGATION EXPENSES AND FEES 2 Defendant shall make no request of the People to pay its attorney fees,expert witness fees and 3 costs,or any other costs of litigation or investigation incurred to date. 4 21. COUNTERPART SIGNATURES 5 The stipulation for entry of this Final Judgment may be executed by the Parties in j f 6 counterparts. f f 7 22. INCORPORATION OF EXHIBITS 8 Exhibits"A"through"D-2"are incorporated herein by reference. 9 23. MODIFICATION 10 The injunctive provisions of this Final Judgment may be modified only on noticed motion by 11 one of the Parties with approval of the Court,or upon written consent by all of the Parties and the 12 approval of the Court. 1 i 13 24. STATUS REPORTS 14 Beginning twelve(12)months after entry of this Final Judgment,for as long as the injunctive 15 provisions of this Final Judgment remains in effect,Defendant shall submit an annual status report to 16 the People's representatives listed in Paragraph 8 above. 17 The status report shall include the following: (1)a brief summary of the actions Defendant has I 18 taken at the corporate level related to California Facilities during the previous year in order to comply 19 with its obligations under this Final Judgment; (2) copies of any notices of violation that Defendant 4 i 20 received pertaining to environmental matters covered by Paragraph 4 above, (3)copies of any return I 21 to compliance submitted by Defendant in response to any notices of violation above; (4)summaries 22 of corrective measures taken as a result of any notices of violation issued to J.C.Penney; (5) i 23 summaries of any penalty amounts Defendant paid to any California governmental agency for alleged 24 noncompliance with any environmental statute or regulation arising from business operations in I 25 California covered by Paragraph 4 above and related to this action;and(6) disclose and provide a 26 copy of the Third-Party Contractor's annual audit statement,as described in Paragraphs 4.4.c and s i 27 4.4.d. 28 17 STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION