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1 16. ABILITY TO INSPECT AND COPY RECORDS AND DOCUMENTS <br /> 2 On reasonable notice, Defendant shall pen-nit any duly authorized representative of the <br /> 3 People to inspect and copy records and documents as they deem reasonably necessary to <br /> 4 determine compliance with the terms of this Final Judgment. Nothing in this paragraph is <br /> 5 intended to require access to or production of any documents that are protected from production <br /> 6 or disclosure by the attorney-client privilege, attorney work product doctrine, any other applicable <br /> 7 privilege, defense, exemption, or inununity afforded to Defendant under applicable law, nor does <br /> 8 it waive any of the objections or defenses to which Defendant would be entitled in responding to <br /> 9 requests for documents made by subpoena or other formal legal process or discovery. This <br /> 10 obligation shall not require Defendant to alter its nonnal document-retention policies (including, <br /> 11 but not limited to, policies regarding backup tapes for electronic documents);provided, however, <br /> 12 that Defendant's policies must comply with Health and Safety Code Chapters 6.5 and 6.95; <br /> 13 Health and Safety Code sections 117600, et seq.; and their implementing regulations as <br /> 14 applicable,to the extent those provisions apply to Defendant's California Facilities. The Parties <br /> 15 agree that Defendant may not be deemed in violation of this paragraph for failure to maintain <br /> 16 such records unless Defendant fails to exercise reasonable diligence in administering this record <br /> 17 retention requirement. Nothing in this paragraph is intended to limit the authority of any <br /> 18 goverunental agency to inspect Defendant or its records and documents under applicable law. <br /> 19 17. PAYMENT OF LITIGATION EXPENSES AND FEES <br /> 20 Defendant shall make no request of the People to pay its attorney's fees, expert witness fees <br /> 21 and costs, and all other costs of litigation and investigation incurred to date. <br /> 22 18. INTERPRETATION <br /> 23 This Final Judgment was drafted equally by all Parties. The Parties agree that the rule of <br /> 24 construction holding that ambiguity is construed against the drafting party shall not apply to the <br /> 25 interpretation of this Final Judgment. <br /> 26 <br /> 27 <br /> 28 <br /> 16 <br /> STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION <br />