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2 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />13.aaa., 13.ff£, 13.111., or 13.000. of the Complaint. If, after the period set by Plaintiff for <br />Defendants to remedy the violation has passed (or at any time in Plaintiff's discretion if no period <br />for Defendants' remedy is allowed), Plaintiff believes that Defendants remain deficient in <br />compliance with the requirements contained in the provisions of Paragraph 6 of this Stipulation <br />and the Final Judgment entered in this action, Plaintiff may (1) move this Court for appropriate <br />relief, including but not limited to seeking sanctions, contempt or other relief as provided by law <br />for violation of the Final Judgment, or (2) commence a separate enforcement action against <br />Defendants for the alleged violation(s) of the statutes and/or regulations set forth in Paragraph 6 <br />of the Final Judgment entered in this action. A violation by Defendants of the provisions imposed <br />by Paragraph 6 of the Final Judgment entered in this action shall be considered a claim separate <br />and in addition to any claim that may be made by Plaintiff, CUPAs, or any other prosecution or <br />enforcement agency for a violation by Defendants of the underlying statutory or regulatory <br />requirements, which may be enforced separately in another proceeding. For potential violations <br />by Defendants of the provisions imposed by Paragraph 6 of the Final Judgment entered in this <br />action, the Office of the Attorney General, when acting in its independent capacity on behalf of <br />the People of the State of California, when electing to pursue a future enforcement action will <br />consider whether it is appropriate to seek monetary relief against Defendants if an amount of <br />penalties has been previously awarded to a CUPA or other enforcement agency for the same <br />underlying statutory or regulatory violation having to do with the same course of conduct. In the <br />event that the People elect to pursue the imposition of injunctive relief for a violation of <br />Paragraph 6 of the Final Judgment entered in this action in addition to an award of fines or <br />penalties to the People, a CUPA, or any other enforcement agency, Defendants reserve all <br />applicable equitable defenses that Defendants may have to the imposition of such an award. <br />(e) Except as provided in Paragraphs 2, 11, and 19-21 below, nothing in this Final <br />Judgment shall restrict or condition the ability of the People, a CUPA, or any other enforcement <br />agency to separately administer, to initiate a separate new enforcement action or take immediate <br />action to protect the public health and/or environment or to enforce state laws or regulations, <br />County Codes, or the provisions of any order or permit issued by any other agency or entity. <br />13 <br />Stipulation for Entry of Final Judgment and Permanent Injunction <br />