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1 5 . 5 Payments and Expenditures 2 The payment of all civil penalties, reimbursement of cost payments and other expenditures 3 set forth in paragraphs 5 . 1 , 5 .2, and 5 .4, above, shall be made by checks and delivered to the District 4 Attorney' s Office for the County of San Joaquin, Attention : Celeste Kaisch, Deputy District 5 Attorney, for distribution. Pursuant to the terms of this Final Judgment and Government Code 6 section 26506 and without objection by Defendant, the above-referenced payments shall be 7 distributed and used as herein requested by Plaintiff and as set forth in Exhibits 134 , 13 -2, C, D4 and 8 D-2 . 9 6. MATTERS COVERED BY THIS FINAL JUDGMENT 10 6. 1 This Final Judgment is a final and binding resolution and settlement of all claims , 11 violations and causes of action that were asserted or could have been asserted within the scope of the 12 allegations specifically set forth in the Complaint against Defendant and its officers, directors and 13 employees through January 14, 2019 regarding the Included Facilities ("Covered Matters" .) Any 14 claim, violation, or cause of action that is not a Covered Matter is a "Reserved Claim . " Reserved 15 Claims include, without limitation, any violation unknown to the People at the time of filing of the 16 Complaint herein, and any violation that occurs after the filing of the Complaint, and any claim or 17 cause of action against Defendant for performance of cleanup, corrective action, or responsive action 18 for any actual past or future release, spill, or disposal of any hazardous waste, hazardous substance, 19 hazardous material, universal waste, or any other material, substance, or waste . The People reserve 20 the right to pursue any Reserved Claim, and Defendant reserves its defenses against any Reserved 21 Claim. Nothing in this paragraph shall be interpreted to limit or restrict any claims that the People 22 may assert against any independent contractor or subcontractor of Defendant. 23 6 .2 . In any subsequent action that may be brought by the People based on any Reserved 24 Claim, Defendant agrees that it will not assert that failing to pursue any Reserved Claim as part of 25 this action constitutes claim-splitting. 26 6. 3 . The continuing effect of paragraph 6. 1 is expressly conditioned on Defendant' s 27 payment and expenditure of all amounts required under this Final Judgment and compliance with the 28 injunctive terms herein. 12 STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION