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I personal jurisdiction over the Parties to this Consent Judgment. <br /> 2 4. SETTLEMENT OF DISPUTED CLAIMS <br /> 3 Defendant expressly denies the allegations in the Complaint and the Consent <br /> 4 Judgment. The Consent Judgment is not an admission by Defendant regarding any issue <br /> 5 of law or fact in the above-captioned matter or of any violation of any law. The Parties <br /> 6 enter into this Consent Judgment pursuant to a compromise and settlement of disputed <br /> 7 claims set forth in the Complaint for the purpose of furthering the public interest. <br /> 8 Defendant waives its right to a hearing on any matter covered by the Complaint prior to the <br /> 9 entry of this Consent Judgment. <br /> 10 5. PAYMENTS FOR PENALTIES, COST REIMBURSEMENT, <br /> 11 ENVIRONMENTAL PROTECTION ENFORCEMENT AND OTHER <br /> 12 PROJECTS <br /> 13 5.1 Amount of Payment: <br /> 14 Defendant will pay a total of$474,422.00 to be allocated as follows: <br /> 15 a. $109,000.00 in civil penalties under the Business and Professions <br /> 16 Code § 17200 to be split as follows: <br /> 17 1. $43,600.00 Monterey County District Attorney <br /> 18 2. $21,800.00 San Joaquin County District Attorney <br /> 19 3. $21,800.00 San Bernardino County District Attorney <br /> 20 4. $21,800.00 Los Angeles County District Attorney <br /> 21 b. $109,000.00 in lieu of civil penalties to further environmental law <br /> 22 enforcement in California to be split as follows: <br /> 23 1. $25,000.00 to Westerns States Project to be used to pay for the <br /> 24 Spring 2006 Environmental Law Enforcement Training Class <br /> 25 produced in conjunction with FLETC in San Luis Obispo. <br /> 26 2. $25,000.00 to California Hazardous Materials Investigators <br /> 27 Association <br /> 28 3. $12,500.00 to the California District Attorney's Association <br /> -5- <br /> 324/017851-0005 CONSENT AGREEMENT AND STIPULATION FOR <br /> 645783.01 a09/27/05 ENTRY OF FINAL JUDGMENT <br />