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EXHIBIT C - CIVIL PENALTIES AND COSTS <br />* Pursuant to the terms of the Stipulation for Entry of Final Judgment, Target shall pay the Attorney General's <br />portion of civil penalties in the total amount of $2,125,000.00 pursuant to Business and Professions Code section <br />17200 at seq., Health and Safety Code section 25515.2 and costs in the sum of $1,250,000.00. The two <br />separate checks shall be made payable to the "California Department of Justice -Litigation Deposit Fund." The <br />checks shall bear on its face the case name ("People v. Target") and the internal docket number for this matter <br />(OK2009900940). Those separate portions of the money paid to the Attorney General pursuant to this Stipulated <br />Judgment shall be administered by the California Department of Justice and shall be used by the Environment <br />Section of the Public Rights Division of the Attorney General's Office, until all funds are exhausted, for any of the <br />following purposes: (1) implementation of the Attorney General's authority to protect the environment and natural <br />resources of the State pursuant to Government Code section 12600 at seq. and as Chief Law Officer of the <br />State of California pursuant to Article V, section 13 of the California Constitution; (2) enforcement of laws related <br />to environmental protection, including, but not limited to, Chapters 6.5 and 6.95, Division 20, of the California <br />Health and Safety Code; (3) enforcement of the Unfair Competition Law, Business and Professions Code section <br />17200, at seq., as it relates to protection of the environment and natural resources of the State of California; and <br />(4) other environmental actions which benefit the State of California and its citizens as determined by the <br />Attorney General. Such funding may be used for the costs of the Attorney General's investigation, filing fees and <br />other court costs, payment to expert witnesses and technical consultants, purchase of equipment, laboratory <br />analyses, personnel costs, travel costs, and other costs necessary to pursue environmental actions investigated <br />or initiated by the Attorney General for the benefit of the State of California and its citizens. The payment, and <br />any interest derived therefrom shall solely and exclusively augment the budget of the Attorney General's Office <br />as it pertains to the Environment Section of the Public Rights Division and in no manner shall supplant or cause <br />any reduction of any portion of the Attorney General's budget. <br />** §25515.2: Target shall pay $255,000.00 as civil penalties pursuant to section 25515.2 of the Health and <br />Safety Code, to the Riverside County District Attorney's Office. Said sum will be paid in the form of a check made <br />payable to the District Attorney, County of Riverside. <br />§17200: Target shall pay $382,500.00 to the Riverside County District Attorney's Office as civil penalties for <br />violations of Business and Professions Code section 17200. Pursuant to Business and Professions Code <br />section 17206(b), said sum will be paid in the form of a check made payable to the District Attorney, County of <br />Riverside; sums to be distributed as follows: 100 percent will be deposited into the consumer protection <br />prosecution account in the General Fund of Riverside County. <br />*** Pursuant to Government Code section 26506, any civil penalties recovered in a civil action brought jointly in <br />the name of the People of the State of California by the Attorney General and any combination of one or more <br />district attorneys or city attorneys shall be paid as approved by the Court. <br />**** Seventy -Eight Thousand and Five Hundred Dollars ($78,500.00) is restricted to the Orange County Health <br />Care Agency/Environmental Health and is to be placed in a special revenue account. These funds are to be used <br />for the implementation and enforcement of the Hazardous Waste Program for items including, but not limited to, <br />program enhancements, educational materials, training, compliance investigations, personnel cost and program <br />equipment. Said payment shall be made in the form of a check made payable to the County of Orange/Auditor- <br />Controller. <br />Exhibit C to Final Judgment and Permanent Injunction on Consent in People v. Target Corporation (RG09457686) Page 7 of 7 <br />