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I H. EFFECT OF CONSENT JUDGMENT
<br /> 2 1. Except as expressly.provided in this Consent Judgment,nothing herein is intended,
<br /> 3 nor shall it be construed,to preclude the People, or any state, county, or local agency, department
<br /> 4 1 board or entity, or any CUPA,from exercising its authority under any law, statute, or regulation.
<br /> 5 I. MATTERS COVERED AND RESERVED CLAIMS
<br /> 6 1 This Consent Judgment is a final and binding resolution and settlement of all
<br /> 7 claims, violations,and causes of action alleged by the People against UHC in the First Amended
<br /> 8 1 Complaint through the date of entry of this Consent Judgment and of all claims,violations,or
<br /> 9 causes of action,which could have been asserted by the People based on the allegations that are
<br /> 10 the subject of the First Amended Complaint, against UHC its officers,employees, agents,and
<br /> 11 attorneys. The matters described in the previous sentence are"Covered Matters." The People
<br /> 12 reserve the right to pursue any claim,violation, or cause of action that is not a Covered Matter
<br /> 13 ("Reserved Claims"). Claims,violations,or causes of action against independent contractors.of
<br /> 14 UHC, if any, are not resolved by this Consent Judgment.
<br /> 15 2. Any claims,violations, or causes of action that are not based on the allegations of
<br /> 16 the First Amended Complaint against UHC,including but not limited to any alleged violations
<br /> 17 that occurred after the date of entry of this Consent Judgment, are not resolved, settled, or
<br /> 18 covered by this Consent Judgment.
<br /> 19 3. Notwithstanding any other provision of this Consent Judgment,Reserved Claims
<br /> 20 include any claims or causes of action for: a)performance of cleanup, corrective action,
<br /> 21 response,or cost recovery actions concerning or arising out of actual past or future releases,
<br /> 22 spills, leaks,discharges or disposal of hazardous materials,hazardous wastes,and/or hazardous
<br /> 23 substances; and b) claims or causes of action relating to the disposal of hazardous materials,
<br /> 24 hazardous wastes, and/or hazardous substances,by UHC,where such disposal is unknown to the
<br /> 25 People as of the date of entry of this Consent Judgment.
<br /> 26 4. In any subsequent action that may be brought in the name of the People based on
<br /> 27 any Reserved Claim(s), UHC agrees that it will not assert that the failure to pursue the Reserved
<br /> 28 Claims as part of this action constitutes claim-splitting,laches or is otherwise inequitable
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<br /> STIPULA'T'ION FOR ENTRY OF FINAL JUDGMENT ON CONSENT
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