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1 Judgment and to address any other matters arising out of or regarding this Final Judgment. <br /> 2 15, ABILITY TO INSPECT AND COPY RECORDS AND DOCUMENTS <br /> 3 Defendant shall permit any duly authorized representative of the People to inspect and copy <br /> 4 records and documents relevant to determine compliance with the terms of this Final Judgment, <br /> 5 provided that the People may not request any internal or third-party audits the Defendant may <br /> 6 choose to conduct related to environmental compliance . This paragraph shall not limit the People ' s <br /> 7 authority to access or obtain information, records and documents pursuant to any other statute or <br /> 8 regulation. <br /> 9 Nothing in this paragraph is intended to require access to or production of any documents <br /> 10 that are protected from production or disclosure by the attorney-client privilege, attorney work <br /> 11 product doctrine, any other applicable privilege, defense, exemption, or immunity afforded to <br /> 12 Defendant under applicable law, nor does it waive any of the objections or defenses to which <br /> 13 Defendant would be entitled in responding to requests for documents made by subpoena or other <br /> 14 formal legal process or discovery. This obligation shall not require Defendant to alter its normal <br /> 15 document-retention policies (including, but not limited to policies regarding backup tapes for <br /> 16 electronic documents) ; provided, however, that Defendant' s policies must comply with Health and <br /> 17 Safety Code Chapters 6 : 5 and 6 . 95 ; and their implementing regulations and any other applicable law, <br /> 18 to the extent those provisions apply to Defendant' s California Facilities . <br /> 19 16 , PAYMENT OF LITIGATION EXPENSES AND FEES <br /> 20 Defendant shall make no request of the People to pay its attorney fees , expert witness fees <br /> 21 and costs, or any other costs of litigation or investigation incurred to date. <br /> 22 17 . COUNTERPART SIGNATURES <br /> 23 The stipulation for entry of this Final Judgment may be executed by the Parties in <br /> 24 counterparts . <br /> 25 18. INCORPORATION OF EXIHBITS <br /> 26 Exhibits "A" through "D-2" are incorporated herein by reference . <br /> 27 19. MODIFICATION <br /> 28 The injunctive provisions of this Final Judgment may be modified only on noticed motion by <br /> 16 <br /> STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION <br />