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1 3. Paragraph 23, page 18 shall be revised to state: <br /> 2 <br /> At any time after the Original Final Judgment,as modified,has been in <br /> 3 effect for sixty-four(64)months(i.e., five(5)years and four(4)months <br /> 4 from April 3, 2013) and Defendant has paid any and all amounts due under <br /> 5 the Original Final Judgment, as modified,the Defendant may provide <br /> 6 notice to the Court(which shall be served on the Parties)that the injunctive <br /> 7 provisions of the Original Final Judgment,as modified, should expire and <br /> 8 have no further force and effect("Notice of Termination"). The injunctive <br /> 9 provisions of the Original Final Judgment,as modified,will be of no <br /> 10 further force or effect sixty(60)days thereafter,unless the People file a <br /> 11 motion contesting the expiration of any injunctive provisions within forty <br /> 12 (40)days of receipt of the Notice of Termination. In the event that such <br /> 13 motion is filed, none of the injunctive provisions of the Original Final <br /> 14 Judgment,as modified, contested in the People's motion will terminate <br /> 15 pending the Court's ruling on the motion. The People reserve the right to <br /> 16 contest termination exclusively on the grounds that Defendant has not <br /> 17 substantially complied in all material respects with the injunctive <br /> 18 provisions of the Original Final Judgment, as modified,or has not been <br /> 19 reasonably diligent in pursuing the actions described in Paragraph 4.2.a, <br /> 20 and to offer any evidence relevant to such motion. Defendant reserves its <br /> 21 rights to respond to any ground raised in the People's motion and to offer <br /> 22 any evidence relevant to such motion. The injunctive provisions in the <br /> 23 Original Final Judgment, as modified,will expire and be of no further force <br /> 24 or effect unless the Court(upon consideration of the Parties'pleadings and <br /> 25 arguments, if any)determines that the expiration of the provision at issue <br /> 26 would not be in the interest of justice,because Defendant has not <br /> 27 substantially complied in material respects with such provision or has not <br /> 28 been reasonably diligent in pursuing the actions described in Paragraph <br /> 9 <br /> STIPULATION TO MODIFY FINAL JUDGMENT AND PERMANENT INJUNCTION <br /> 667947.1 <br />