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I <br /> ♦ i <br /> 1 2, I am familiar with and have reviewed the contents of Plaintiff s filings in this matter <br /> i <br /> 2 Attached hereto as Exhibit"1"is a true and correct copy of the Stipulation for Entry of <br /> 3 Final Judgment and Final Judgment("Final Judgment')in this case. ' <br /> 4 3. Within two(2)business days of filing of the Complaint for Injunction, Civil Penalties <br /> 5 and Other Equitable Relief("Complaint"), and of the instant motion, and within two (2) <br /> 6 business days of the lodging of the Final Judgment with the Court, our office will scan <br /> 7 the Complaint,the Motion and the Final Judgment and serve them electronically to each <br /> 8 District Attorney's Office in the State of California that has a"Covered Facility"within r <br /> 9 its jurisdiction and that is not part of the prosecution team which negotiated the Final } <br /> 10 Judgment lodged with this Court for approval. <br /> 11 4. Within two(2)business days of filing of the Complaint and the Motion, and within two g <br /> 12 (2)business days of the lodging of the Final Judgment,my office will scan the <br /> 13 Complaint,Motion and Final Judgment and forward them electronically to each Certified <br /> 14 Unified Program Agency(CUPA)in the State of California that has any"Covered <br /> 15 Facility"within its jurisdiction. <br /> 3' <br /> 16 5. I have made inquiries and determined that there are no pending enforcement matters by <br /> 17 prosecutors against KMART in the State of California arising from alleged violations of <br /> 18 Chapter 6.5 or Chapter 6.95,Division 20,of the Health and Safety Code as of this date. I <br /> 19 have further consulted counsel of record for KMART in this matter,and with corporate <br /> 20 counsel for KMART,and have been informed that there are no known enforcement <br /> i <br /> 21 matters pending elsewhere in the State of California arising from alleged violations of <br /> 22 Chapter 6.5 or Chapter 6.95,Division 20,of the Health and Safety Code as of this date. <br /> a <br /> 23 6. Prior to the court date scheduled for obtaining the Court's signature on the Final <br /> 24 Judgment, I shall file another Declaration confirming that I have completed the tasks set <br /> 25 forth above in this Declaration. s <br /> 3 <br /> 26 I declare under penalty of perjury under the laws of the State of California that the <br /> 27 foregoing is true and correct. <br /> :x <br /> 28 <br /> i <br /> -2- <br /> DECLARATION OF DAVID J.IREY RE:NOTIFICATION OF POTENTIALLY INTERESTED PARTIES <br />