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S � 1 limit any rights of the People to seek any other relief or remedies provided by law,or the rights of 2 Defendant to defend against any request of the People for such other relief or remedies. 3 7. MATTERS COVERED BY THIS FINAL JUDGMENT 4 7.1 This Final Judgment is a final and binding resolution and settlement of all claims, 5 violations or causes of action expressly alleged by the People in the Complaint or claims that could 6 have been asserted within the scope of the allegations set forth in the Complaint("Covered Matters"), 7 against Defendant and its subsidiaries,affiliates,predecessors and corporate parents and each of their 8 affiliates and parents,successors,heirs,assigns and their respective shareholders,officers,directors, 9 partners, employees,agents,representatives,property owners,and facility operators("Entities 10 Covered by Final Judgment"). The People further covenant not to sue the Entities Covered by Final 11 Judgment for any Covered Matter. Any claim,violation,or cause of action that is not a Covered 12 Matter is a"Reserved Claim." Reserved Claims include,without limitation,any violation that occurs 13 after the Court's entry of this Final Judgment. Nothing herein shall be interpreted to restrict any 14 claims that the People may assert against any independent contractors or subcontractors of the 15 Facilities for violations of applicable laws by such parties. The People reserve the right to pursue any 16 Reserved Claim,and Defendant reserves its defenses against any Reserved Cl aim. 17 7.2 Any claims or causes of action against Defendant for performance of cleanup, 18 corrective action,or response action for any actual past or future release,spill,or disposal of any 19 hazardous waste,hazardous substance,hazardous material,universal waste,sharps waste, 20 pharmaceutical waste,photo waste with silver,or any other material,substance or waste,that is 21 caused or contributed to by the Defendant at or from its California Facilities,and any claims or 22 causes of action for performance of cleanup,corrective action,or response action relating to 23 Defendant's disposal of same that are discovered by the People after execution of this Agreement are 24 Reserved Claims. 25 7.3 In any subsequent action that may be brought by the People based on any Reserved 26 Claim,Defendant agrees that it will not assert that failing to pursue the Reserved Claims as part of 27 this action constitutes claim-splitting. This Paragraph does not affect any statute of limitations,if 28 any,which may be applicable to any Reserved Claim or claims otherwise excluded from this Final 10 sf-3138122 Stipulation for Entry of Final Judgment and Permanent Injunction