COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

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I INTRODUCTION 2 Plaintiff, the People of the State of California ("Plaintiff'), will file its Complaint to initiate 3 this matter as a civil action, and Defendants, Chevron U.S.A. Inc. and Chevron Stations Inc. 4 (hereafter collectively "Defendants" and individually "Defendant"), will accept service of the S Complaint through their counsel. Plaintiff is appearing through its attorneys Kamala D. Harris, 6 Attorney General.of the State of California, by Brett J. Morris, Deputy Attorney General, Paul 7 Gallegos, District Attorney of Humboldt County, by Matthew C. Maclear, Deputy District 8 Attorney, Larry D. Morse, District Attorney of Merced County,by Matthew C. Maclear, Deputy 9 District Attorney, Clifford Newell, District Attorney of Nevada County, by Matthew C. Maclear, 10 Deputy District Attorney, and Jan Scully, District Attorney of Sacramento County, by Douglas 11 Whaley, Deputy District Attorney. Defendants are appearing through their attorneys Todd 12 Littleworth and Latham &Watkins LLP, by Karl S. Lytz. 13 The Parties, after opportunity for review by their respective counsel, hereby stipulate and 14 consent to the entry by the court of Final Judgment and Permanent Injunction ("Final Judgment") 15 on the terms set forth below. 16 JURISDICTION 17 The Parties stipulate and agree that the Superior Court of California, County of Alameda, 18 has subject matter jurisdiction over the matters alleged in this action and personal jurisdiction 19 over the Parties. 20 APPLICABILITY 21 1. Plaintiff alleges that on or before August 1, 2011, Defendants have committed violations 22 of requirements imposed by the California Health and Safety Code and related implementing 23 regulations, county codes, local ordinances, permits or orders that govern (a) the operation and 24 maintenance of underground storage tanks ("USTs") and UST systems and (b) the handling of 25 hazardous materials, hazardous wastes and hazardous substances generated by operation of USTs, 26 UST systems, and motor vehicle maintenance, in the State of California at Defendants' facilities 27 identified in Exhibit A, a document which is incorporated herein by reference (hereinafter 28 collectively referred to as the "Covered Facilities"). 2 Stipulation for Entry of Final Judgment and Permanent Injunction