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<br /> In this Final Judgment shall Unlit any rights of the People to Seek any other relief or remedies provided
<br /> by la%v. or limit the rights of Defendant to defend against any requeSt Of the People for Such other relief
<br /> or remedies.
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<br /> 7. MATTERS COVERED BY THIS FINAL JUDGIVIENT
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<br /> 7.1 This Final Judgment is a final and binding resolution and settlement of all claims, violations
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<br /> or causes of action expressly alleged by the People in the Complaint or claims that could have been
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<br /> asserted within the scope of the allegations set forth in the Complaint("Covered Matters"), against
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<br /> Defendant and its subsidiaries, affiliates and corporate parents, and each of their affiliates and parents,
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<br /> Facilities, successors, heirs, assigns, and each of their respective officers, directors, partners, employees,
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<br /> agents, representatives, property owners,and facility operators ("Entities Covered by Final Judgment").
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<br /> The People further covenant not to sue the Entities Covered by Final Judgment for any Covered Matter.
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<br /> Any claim,violation,or cause of action that is not a Covered Matter is a"Reserved Claim."Reserved
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<br /> Claims include, without limitation, any violation that occurs after the Court's entry of this Final
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<br /> Judgment.The People reserve the right to pursue any Reserved Claim, and Defendant reserves its
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<br /> defenses against any Reserved Claim.
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<br /> 7.2 Any claims or causes of action by the People against Defendant for performance of cleanup,
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<br /> corrective action, or response action for any actual past or future release, spill, or disposal of hazardous
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<br /> waste or hazardous substances,universal waste, sharps waste,pharmaceutical waste, or photo waste with
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<br /> silver, or any other material, substance, or waste,that is caused or contributed to by Defendant at or from
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<br /> its Facilities, and any claims or causes of action for performance of cleanup,corrective action, or
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<br /> response action relating to Defendant's disposal of the same that are discovered by the People after
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<br /> execution of this Agreement are Reserved Claims. For purposes of this Final Judgment,the term
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<br /> "release" includes, but is not limited to,any spilling, leaking,pumping, injecting, escaping, leaching,
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<br /> dumping, or disposing into the environment.
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<br /> 73 In any subsequent action that may be brought by the People based on any Reserved Claim,
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<br /> Defendant agrees that it will not assert that failing to pursue the Reserved Claim(s)as part of this action
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<br /> constitutes claim-splitting.This Paragraph does not affect any statute of limitations, if any, which may be
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<br /> applicable to any Reserved Claim(s) otherwise excluded from this Final Judgment and does not prohibit
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<br /> STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION
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