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0 <br /> I on-site storage of cured coating waste in an appropriate container and <br /> 2 arranging for disposal at a licensed hazardous waste disposal facility. <br /> 3 5.2 Procedure for Payment: Defendant shall satisfy its payment obligations to <br /> 4 the Plaintiff under Paragraph 5.1 as follows: <br /> 5 a. Payment of civil penalties, including distribution of vouchers, shall be <br /> 6 made within 30 days of entry of this Consent Judgment. <br /> 7 b. Reimbursement of costs of investigation shall be made within 30 days <br /> 8 of entry of this Consent Judgment. <br /> 9 5.3 Delivery of Payment Checks: <br /> 10 a. All payments shall be delivered to: <br /> 11 Office of the District Attorney, Monterey County <br /> Attention: Matt Bogoshian, Deputy District Attorney <br /> 12 Monterey County Courthouse, Room 301 <br /> 1200 Aguajito Road <br /> 13 Monterey, CA 93940 <br /> 14 b. A photocopy of all payments made pursuant to Paragraph 5.1 shall <br /> 15 be sent, at the time that they are delivered for payment, to Plaintiff <br /> 16 representative as identified in Paragraph 8. <br /> 17 6. INJUNCTIVE RELIEF <br /> 18 Pursuant to the California Health and Safety Code, Section 25181, the Business and <br /> 19 Professions Code Section 17203 and the Court's equitable powers, Defendant shall <br /> 20 manage its coating waste in accordance with applicable laws and regulations, which may <br /> 21 include treating the coating in accordance with the CESW provisions, accumulating the <br /> 22 cured coating waste in a labeled container in each store, and arranging for the waste to be <br /> 23 disposed of at a licensed disposal facility as set forth in paragraph 5.1(e) of this Consent <br /> 24 Judgment. Any violation of the injunction required by this Consent Judgment shall be <br /> 25 considered separate and in addition to any violation of those underlying provisions. <br /> 26 7. MATTERS COVERED BY THIS CONSENT JUDGMENT <br /> 27 7.1 Except as provided in Paragraph 7, the Consent Judgment is a final and <br /> 28 binding resolution and settlement of all claims, violations or causes of action alleged by <br /> -7- <br /> 324/017851-0005 CONSENT AGREEMENT AND STIPULATION FOR <br /> 645783.02 a]0/04/05 ENTRY OF FINAL JUDGMENT <br />