Laserfiche WebLink
1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />and G, any party filing a motion relating to this Consent Judgment shall provide. at least fourteen <br />(14) days written notice to the affected parties and all parties to the matter shall promptly meet <br />and confer and negotiate in good faith in an effort to resolve any dispute without judicial <br />� intervention. <br />R. ABILITY TO INSPECT AND COPY RECORDS AND DOCUMENTS <br />1. Upon reasonable notice and subject to all of the defenses UHC would have to a <br />request for documents made by subpoenas or other formal legal process or discovery, UHC shall <br />permit any duly authorized representative of the People to inspect and copy UHC's records and <br />documents to determine whether UHC is in compliance with the terms of this Consent Judgment. <br />Nothing in this Paragraph is intended to require access to or production of any privileged <br />11 II documents. <br />12 <br />13 <br />14, <br />15 <br />16 <br />17 <br />18 <br />19 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />( 27 <br />28 <br />S: PAYMENT OF LITIGATION EXPENSES AND FEES <br />1. UHC shall pay its own attorneys fees, expert witness fees and costs and all other <br />costs of litigation and investigation incurred by UHC in connection with this matter. <br />T. INTERPRETATION OF CONSENT JUDGMENT <br />1. This Consent Judgment was drafted equally by the signatories hereto. The <br />signatories agree that the rule of construction holding that ambiguity is construed against the <br />drafting party shall not apply to the interpretation of this Consent Judgment. <br />U. COUNTERPART SIGNATURES <br />i. This Consent Judgment may be executed in counterpart signatures. <br />V. INTEGRATION <br />1. This Consent Judgment constitutes the entire agreement between the People and <br />UHC and may not be amended or supplemented except as provided for in the Consent Judgment. <br />W. MODIFICATION OF CONSENT JUDGMENT <br />I . This Consent Judgment may be modified only by the Court or upon written <br />consent by the parties and the written approval of the Court. <br />X. TERMINATION OF PERMANENT INJUNCTION <br />1 After this Consent Judgment has been in effect for five (5) years from the date of <br />14 <br />STIPULATION FOR ENTRY OF FINAL JUDGMENT ON CONSENT <br />