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I Water Resources Control Board, Office of Enforcement, 801 K Street, Suite 2300, Sacramento 2 CA 95814. If Defendants do not pay $1,000,000 within 15 calendar days of the Effective Date of 3 this Stipulation, the State Water Board may rescind this Stipulation and proceed to litigate this 4 matter. 5 II. SUSPENDED CIVIL PENALTIES 6 16. The Parties stipulate that if Defendants fail to comply with any of the General 7 Injunctive Provisions or Specific Injunctive Provisions under paragraphs 8 —13 (collectively 8 referred to as the "Injunctive Provisions") in this Stipulation and Judgment, then Defendants will 9 be liable for suspended civil penalties as follows: 10 • Defendants Stars Holding Co., LLC and Nasrin Amiri shall be jointly and severally liable to ' 11 pay $250,000 if any defendant fails to comply with any of the Injunctive Provisions in this 12 Stipulation and Judgment at the Covered Facility located at 4323 Clayton Road, Concord, 13 County of Contra Costa, State of California. 14 • Defendants Seerat, Inc. and Sukhwinder Singh shall be jointly and severally liable to pay 15 $250,000 if any defendant fails to comply with any of the Injunctive Provisions in this 16 Stipulation and Judgment at the Covered Facility located at 1140 Emerald Bay Road, 17 South Lake Tahoe, County of El Dorado, State of California. 18 • Defendants Meyers -Holding Co., LLC and Reza Amiri shall be jointly and severally liable 19 to pay $250,000 if any defendant fails to comply with any of the Injunctive Provisions in 20 this Stipulation and Judgment at the Covered Facility located at 3208 Highway 50, 21 Meyers, County of El Dorado, State of California if they reopen or fail to remove the 22 tanks as provided in paragraph 8(n) above. 23 • Defendants Tahoe Station, Inc. and Raman Singh shall be jointly and severally liable to pay 24 $250,000 if any defendant fails to comply with any of the Injunctive Provisions in this 25 Stipulation and Judgment at the Covered Facility located at 2304 Lake Tahoe Boulevard, 26 South Lake Tahoe, County of El Dorado, State of California. 27 • Defendants Seerat, Inc., Sukhwinder Singh, and Sarbjit Kang shall be jointly and severally 28 liable. to pay $250,000 if any defendant fails to comply with any of the Injunctive 10 Stipulation for Entry of Final Consent Judgment (Case No. 34-2014-00164107 )