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1 alleged in the First Amended Complaint and personal. jurisdiction over each of them. <br />2 UHC waives its right to a hearing and appeal in ibis matter. <br />3 B. SETTLEMENT OF DISPUTED CLAIMS <br />4 1. The People and UHC enter into this Consent Judgment pursuant to a compromise <br />5 and settlement of disputed claims for purposes of furthering the public interest. The People <br />6 believe that the resolution embodied in this Consent Judgment is fair and reasonable and fulfills <br />7 the People's enforcement objectives; that except as provided in this Consent Judgment, no <br />8 further action is warranted concerning the allegations contained in the First Amended Complaint; <br />9 and that entry of this Consent Judgment is in the best interest of the public. UHC agrees that this <br />10 Consent Judgment is a fair and reasonable resolution of the matters alleged in the First Amended <br />11 Complaint, This Consent Judgment is not an admission by UHC regarding any issue of law or <br />12 fact in this action or of any violation of law, as alleged in the First Amended Complaint. <br />13 C. DEFINITIONS, <br />14 Except where otherwise expressly defined herein, all terms in this Consent Judgment <br />15 1 shall be interpreted consistent with Chapters 6.5 and 6.95 of Division 20 of the California Health <br />16 and. Safety Code and the, regulations promulgated under these chapters. <br />17 1. "UHC Covered Facilities" means the UHC facilities in the State of California that <br />18 fall within definitions C. 7 and C. 8. <br />19 2. "Certified Unified Program Agency" or "CUPA" is the agency certified by the <br />20 1 California Environmental Protection Agency pursuant to the requirements of Chapter 6.11 of the <br />21 California Health and Safety Code and California Code of Regulations, Title 27, to implement <br />22 1 certain State -of California environmental programs within the local agency's jurisdiction and as <br />23 defined in California Health and Safety Code section 25501(g)(1). As, used in this Consent <br />24 Judgment, "CUPA" includes any local agency that has been designated by the CUPA to <br />25 administer Chapters 6.5 and 6.95 of the California Health and Safety Code. <br />26 3. "Hazardous Materials Business Plan," ("HMBP'� as used herein, means a plan <br />27 which meets the requirements of California Health and Safety Code section 25504. <br />28 4. "Hazardous Material," as used herein, means "hazardous material" as that term is <br />2 <br />STIPULATION FOR ENTRY OF FINAL JUDGMENT ON CONSENT <br />