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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />Stipulation for Entry of Final Consent Judgment, attached hereto as Exhibit 1 (Stipulation), in <br />which the State Water Board and Defendants shall be collectively referred to as "Parties," and <br />individually as "Party." <br />THEREFORE, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that <br />judgment is entered as follows: <br />RECITALS <br />A. The State Water Board is a public agency of the State of California. <br />B. Azad Amiri, Haleh Amiri, Nasrin Amiri, Reza Amiri, Harwant Kaur Kang, Sarbjit <br />Singh Kang, Parmjit Singh, Raman Singh, and Sukhwinder Singh are individuals. <br />C. Meyers Holding Co., LLC, and Stars Holding Co., LLC are limited liability <br />companies doing business in the State of California. <br />D. Sacramento/Dunnigan Holding Co., Inc., Tahoe Station, Inc., Tahoe Blue Property, <br />Inc., and Seerat, Inc. are corporations doing business in the State of California. <br />E. The State Water Board filed a First Amended Complaint against Defendants alleging <br />violations of California Health and Safety Code, division 20, chapter 6.7, and California Code of <br />Regulations, title 23, section 2610 et seq. relating to the Defendants' ownership and operation of <br />11 underground storage tank facilities in the State of California. <br />F. The Parties entered into the'Stipulation in a good faith effort to avoid the uncertainty <br />and expense of protracted litigation. <br />G. The Parties stipulated to the entry by this Court of this Final Consent Judgment <br />(Judgment), on the terms set forth below. <br />DEFINITIONS <br />1. For purposes of the Stipulation and the Judgment, unless otherwise specified, the <br />definitions set forth in the California Health and Safety Code sections 25.281 and 25281.5 and the <br />California Code of Regulations, title 23, sections 2610 and 2611, as they exist on the Effective <br />Date of the Stipulation, shall apply to the terms used herein. <br />2 <br />Final Consent Judgment (Case No. 34-2014-00164107) <br />