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1 Station, Inc., Tahoe Blue Property, Inc., and Seerat, Inc. (Defendants). The State Water Board 2 and Defendants shall be collectively referred to as "Parties," and individually as "Party." This 3 Stipulation is effective the day it is signed by the last signatory (Effective Date). 4 RECITALS 5 A. The State Water Board is a public agency of the State of California. 6 B. Azad Amiri, Haleh Amiri, Nasrin Amiri, Reza Amiri, Harwant Kaur Kang, Sarbjit 7 Singh Kang, Parmjit Singh, Raman Singh, and Sukhwinder Singh are individuals. 8 C. Meyers Holding Co., LLC, and Stars Holding Co., LLC are limited liability 9 companies doing business in the State of California. 10 D. Sacramento/Dunnigan Holding Co., Inc., Tahoe Station, Inc., Tahoe Blue Property, 11 Inc., and Seerat, Inc. are corporations doing business in the State of California. 12 E. The State Water Board filed a First Amended Complaint against Defendants alleging 13 violations of California Health and Safety Code, division 20, chapter 6.7, and California Code of 14 Regulations, title 23, section 2610 et seq. relating to the Defendants' ownership and operation of 15 . 11 underground storage tank facilities in the State of California. 16 F. The Parties entered into this Stipulation in a good faith effort to avoid the uncertainty 17 and expense of protracted litigation. 18 G. The Parties stipulate to the entry by this Court of a Final Consent Judgment 19 (Judgment), attached as Exhibit A to this Stipulation, on the terms set forth below. 20 DEFINITIONS 21 1. For purposes of this Stipulation and the Judgment, unless otherwise specified, the 22 definitions set forth in the California Health and Safety Code sections 25281 and 25281.5 and the 23 California Code of Regulations, title 23, sections 2610 and 2611, as they exist on the Effective 24 Date of this Stipulation, shall apply to the terms used herein. 25 JURISDICTION 26 2. The Sacramento County Superior Court has jurisdiction over the subject matter of this 27 action and the Parties to this Stipulation and Judgment. 28 2 Stipulation for Entry of Final Consent Judgment(Case No.34-2014-00164107)