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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 />and pursuant to applicable law. <br />2. Before pursuing any action to enforce any of the terms of this Consent Judgment. <br />the People shall meet and confer with UHC in a good faith attempt to resolve the issue without <br />judicial intervention. To ensure that the meet and confer process is. as productive as possible, th! <br />People will identify at least ten (10) days in advance of the meet and confer, as specifically as the <br />available information allows, the grounds for its motion and the actions that the People believe <br />UHC must take to remedy its noli-compliance and the specific relief, if any, sought by the <br />People. <br />3. Notwithstanding Paragraph G.1, with respect to the following provisions only, the <br />People may move to judicially enforce the terms of the Consent Judgment for violations of <br />Paragraphs E. 2.2, 2.4, 2.5, 3.5-3.12 and 4..2 only in the following circumstances as set forth in a) <br />through d) below, Provided however, the People shall have the right to seek injunctive relief to <br />require the performance of the obligations contained in Paragraphs E. 2. 1, 2.3, 3.1, 3.2, 3.3, 3.4, <br />3.13, 4. 1, and 5.1. <br />a) For violations of these specific injunctive terms subject to a cure, which UHC <br />fails to cure within such time period as may be provided by a local enforcement agency, or if no <br />time is specified for cure in the NOV, within thirty (30) days of the date. of the NOV; <br />b) For Multiple Violations of these specific injunctive provisions, as Multiple <br />Violations are defined in Paragraph C.11; <br />c) For violations of these specific injunctive provisions which are not subject to a <br />cure, only in the event such violation is a. Multiple Violation, as defined in Paragraph C.11 of <br />Consent Judgment; and <br />d) For alleged violations associated with the transportation of hazardous waste as <br />specifically set forth in Paragraph E.3.12. <br />4. UHC reserves all rights to oppose any motion brought by the People to enforce <br />any provisions of the Consent Judgment, including but not limited to its ability to assert that it is <br />not liable for the alleged violation due to Force Majeure. <br />9 <br />STIPULATION FOR ENTRY OF FINAL JUDGMENT ON CONSENT <br />