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1 and pursuant to applicable law. 2 2. Before pursuing any action to enforce any of the terms of this Consent Judgment, 3 the People shall meet and confer with UHC in a good faith attempt to resolve the issue without 4 judicial intervention. To ensure that the meet and confer process is as productive as possible,the 5 People will identify at least ten(10)days in advance of the meet and confer,as specifically as the 6 available information allows, the grounds for its motion and the actions that the People believe 7 UHC must take to remedy its noli-compliance and the specific relief,if any, sought by the 8 People. 9 3. Notwithstanding Paragraph G.1, with respect to the following provisions only,the 10 People may move to judicially enforce the terms of the Consent Judgment for violations of 11 Paragraphs E.2.2, 2.4,2.5, 3.5-3.12 and 4..2 only in the following circumstances as set forth in a) 12 through d)below, Provided however, the People shall have the right to seek injunctive relief to 13 require the performance of the obligations contained in Paragraphs Ba 2.1, 2.3, 3.1, 3.2,3.3,3.4, 14 3.13,4.1, and 5.1. 15 a) For violations of these specific injunctive terms subject to a cure,which UHC 16 fails to cure within such time period as may be provided by a local enforcement agency, or if no 17 time is specified for cure in the NOV,within thirty(30)days of the date.of the NOV; 18 b) For Multiple Violations of these specific injunctive provisions, as Multiple 19 1 Violations are defined in Paragraph C.11; 20 c) For violations of these specific injunctive provisions which are not subject to a 21 cure, only in the event such violation is a.Multiple Violation, as defined in Paragraph C.11 of this 22 Consent Judgment; and 23 d) For alleged violations associated with the transportation of hazardous waste as 24 specifically set forth in Paragraph E.3,12. 25 4. UHC reserves all rights to oppose any motion brought by the People to enforce 26 any provisions of the Consent Judgment, including but not limited to its ability to assert that it is 27 not liable for the alleged violation due to Force Majeure. 28 9 STTPULATION FOR ENTRY OF FINAL JUDGMENT ON CONSENT