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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 />by the attorney-client privilege, attorney work product doctrine, any other applicable privilege, <br />defenses, exemptions, or immunities afforded to Target under applicable law, nor does it waive <br />any of the objections or defenses to which Target would be entitled in responding to requests for <br />documents made by subpoena or other formal legal process or discovery. This obligation shall <br />not require Target to alter its normal document retention policies (including but not limited to <br />policies regarding backup tapes for electronic documents); provided, however, that Target's <br />policies must comply with Health and Safety Code Chapter 6.5 and California Code of <br />Regulations, Title 22. <br />16. PAYMENT OF LITIGATION EXPENSES AND FEES <br />Target shall pay its own attorney fees, expert witness fees and costs and all other costs of <br />litigation and investigation incurred to date. <br />17. INTERPRETATION <br />This Final Judgment on Consent was drafted equally by all parties. The parties agree that <br />the rule of construction holding that ambiguity is construed against the drafting party shall not <br />apply to the interpretation of this Final Judgment on Consent. <br />18. INTEGRATION <br />This Final Judgment on Consent constitutes the entire agreement between the parties and <br />may not be amended or supplemented except as provided for in the Final Judgment on Consent. <br />No oral representations have been made or relied upon other than as expressly set forth herein. <br />19. MODIFICATION OF FINAL JUDGMENT ON CONSENT <br />This Final Judgment on Consent may be modified only on noticed motion by one of the <br />parties with approval of the Court, or upon written consent by all of the parties and the approval <br />of the Court. <br />20. STATUS REPORTS <br />Beginning six (6) months after entry of this Final Judgment on Consent, for as long as this <br />Final Judgment on Consent remains in effect, Target shall submit a semi-annual status report to <br />the People's representatives listed in Section 8 above. The status report shall: briefly summarize <br />the actions that Target has taken during the previous six months in order to comply with its <br />on <br />13 <br />V. <br />