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I request, on an annual basis, meet to describe to the People's representatives the status of 2 Defendant's compliance with Paragraph 4, 4.1, and 4.2 of this Final Judgment, and any reverse 3 logistics program Defendant may have in place. 4 23. TERMINATION OF FINAL JUDGMENT 5 At any time after this Final Judgment has been in effect for five (5) years, and Defendant 6 has paid any and all amounts due under the Final Judgment, any party may provide notice to the 7 Court (which shall be served on all parties)that the injunctive provisions of this Final Judgment 8 should expire and have no further force and effect("Notice of Termination"). The injunctive 9 provisions of this Final Judgment will be of no further force or effect sixty (60) days thereafter, 10 unless the People file a motion contesting the expiration of any injunctive provisions within forty 11 (40) days of receipt of the Notice of Termination. In the event that such motion is filed, none of 12 the injunctive provisions of the Final Judgment contested in the People's motion will terminate 13 pending the Court's ruling on the motion. The People reserve the right to contest termination 14 exclusively on the grounds that Defendant has not substantially complied in all material respects 15 with the injunctive provisions of paragraph 4.1 of the Final Judgment or has not been reasonably 16 diligent in pursuing the actions described in Paragraph 4.2.a, and to offer any evidence relevant to 17 such motion. Defendant reserves its rights to respond to any ground raised in the People's motion 18 and to offer any evidence relevant to such motion. The injunctive provisions in the Final 19 Judgment will expire and be of no further force or effect unless the Court(upon consideration of 20 the Parties' pleadings and arguments, if any) determines that the expiration of the provision at 21 issue would not be in the interest of justice,because Defendant has not substantially complied in 22 material respects with the provision of paragraph 4.1 of the Final Judgment or has not been 23 24 25 26 27 28 18 STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION