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