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1 11 Consent Judgment and to address any other matters arising out of or regarding this Consent <br />2 Judgment. The Parties shall meet and confer prior to the filing of any motion relating to this <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />ld <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 />Consent Judgment, including any Enforcement Motion as required by Paragraph 6.1., and shall <br />negotiate in good faith in an effort to resolve any dispute without judicial intervention. <br />17. NON-DISCHA.RGEABILITY OF OBLIGATIONS <br />Payments required by this Consent Judgment are not dischargeable in bankruptcy <br />18. ABILITY TO INSPECT AND COPY RECORDS AND DOCUMENTS <br />On reasonable notice and subject to all of the defenses Flying J would have to requests <br />for documents made by subpoena or other formal legal process or discovery, Flying J shall <br />permit any duly authorized representative of the People to inspect and copy Flying J's records <br />and documents to determine whether Flying J is in compliance with the terms of this Consent <br />Judgment. Such documents include, but are not limited to, Flying J's designated UST <br />operator reports. Nothing in this Paragraph is intended to require access to or production of <br />any documents that are protected by the attorney-client privilege, attorney work product <br />doctrine or any other applicable privilege afforded to Flying J under law <br />19. PAYMENT OF LITIGATION EXPENSES AND FEES. <br />Flying J shall pay its own attorney fees, expert witness fees and costs and all other <br />costs of litigation and investigation incurred to date. <br />20. INTERPRETATION <br />This Consent Judgment was drafted equally by all Parties. The Parties agree that the <br />rule of construction holding that ambiguity is construed against the drafting Party shall not <br />apply to the interpretation of this Consent Judgment. <br />21. COUNTERPART SIGNATURES <br />This Consent Judgment may be executed by the Parties in counterpart. <br />22. COOPERATION BY FLYING J <br />Flying J shall cooperate with the People in addressing violations of environmental <br />laws by any of Flying J's third -party contractors, should such violations come to light. On the <br />People's request and upon reasonable notice, Flying J will provide documents in its <br />CONSENT JUDGMENT <br />19 <br />