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3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />12 1 <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 />defenses, exemptions, or immunities afforded to Wal-Mart under applicable law, nor does it <br />Wailve any of the objections or defenses to which Wal-Mart would be entitled in responding to <br />requests for documents made by subpoena or other formal legal processor discovery This <br />obligation shall not require Wal-Mart to alter its normal document retention policies (including <br />bUt not. limited to policies regarding backup tapes for electronic documents); provided., however, <br />that Wal -Mart's policies must comply with Health and Saf)6t 1 Code Chapter 6.5 and California <br />Code of Regyulations, Title 22, Nothing in this paragraph is intended to limit the authority of any <br />,gov . <br />. ernmental agency to inspect Wal-Mart or Wal-Mart records and documents under applicable <br />I <br />-cable <br />IaNv. <br />17. PAYMENT OFMI—TIGATION EXPENSES. ANDEVOKS, <br />Wal-Mart shall pay its own attorney fees,, expert witness fees and costs and all other costs <br />of litigation and inves0gation incurred to date. <br />18, tNTI*,�IPRETATIQN <br />This Consent Judgment was drafted equally by all Parties. The Pard I es agree that the rule of <br />construction holding, that ambiguity is construed against the drafting party shall not apply to the <br />interpretation of this Consent Judginent. <br />19. <br />This Consent Judgpent. may be executed by the Parties in counterpart. <br />20. RNIRY AFTER NOTICM MOTION <br />The Parties seek approval of this Consent Judgment on noticed motion and have requested <br />that the court make a. determination that the Consent Judgment is fair and in the public interest. <br />21. INTEGRA110N <br />This Consent Judgment constitutes the entire agreement between the Parties and may not be <br />I amended or supplemented except as provided for in. the Consent Judgment. No oral <br />representations have been made or relied upon other than as expressly set forth herein. <br />22. MODIFICATION OF CONSENT ,JUDGWM <br />This Consent Judgment may be modified only on noticed motion by one of the Parties with <br />approval of the court, or upon written consent by all of the Parties and. the approval of the court. <br />is <br />STIPULATION FOR ENTRY O1° FINAL JUDGMENT ON CONSENT <br />