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XAVIER BECERRA Attomey General of California MARGARITA PADILLA . Supervising Deputy Attomey General LAURAJ.ZucKERMAN
Deputy Attorney General State Bar No. 161896
1515 Clay Street, 20th Floor P.O. Box 70550 Oakland, CA 94612-0550 Telephone: (510) 879-1299
· F�85510) 622-2270
E- · : [email protected] for Plaintiff People of the State of California ex rel. Barbara A. Lee, Director, California Department of Toxic Substances Control
EXEMPT FROM FILING FEES GOVERNMENT COJ)E § 6103
FILED ENDORSED
SEP 2 2 2017
--- r.-,
r � •. --, }tr I If
D•.pu\y Clerk
.,,..-
SUPERIOR COURT OF TilE STATE OF CALIFORNIA COUNTY OF SACRAMENTO
15 PEOPLEOFTHESTAU:OF CaseNo.34-2017-00217931 · CALIFORNIA ex rel Barbara A. Lee,
16 l>irecforof the DEP AR'.I'MENT OF TOXIC FINAL JUDGMENT PURSUANT TO 17 18 19
SUBSTANCES CONIROL, . STIPULATION .
v.
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Plaintiff, (Code of Civil Prpcedure § 664.6)
Trial Date: None set Action Filed: August 23, 2017
20 . CALIFORNIA ELEcrRONIC ASSET 21 22
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RECOVERY, a California corporation,
Defendant
Good cause appearing herein, the Court finds that the settlement between Plaintiff People of 26
the State of California ex rel. Barbara A. Lee, Director of the Department of Toxic Substances Control (''the Department''), and Defendant California Electronic Asset Recovery (''CEAR") is
. FiDal Judgment Pursuant to Stipulation (Case No. 34-2017--00217931)
1 fair and in the public interest. Accordingly, the Stipulation for Entry of Pinal Judgment
2 ("Stipulation") entered into by the Department and CEAR and filed with this Court, a 1rue and
3 · correct copy of which is attached hereto as Exhibit 1, is approved, and this Final Judgment
4 Pursuant to Stipulation is entered as provided in the Stipulation.
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IT IS SO ORDERED.
SEP 2 2 2017.Dated: 2017
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DAVID I. BROWN
OK2014511641 Judge of the Superior Court
90803080.d<K,
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Final Judgment Pursuant to Stipulation (Case No. 34-2017-00217931)
... · .•,11 " . . . . ,.,., . , .. ' . '·'""" .,,,.,.,,.� .. ,- ...... . '
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XAVIER BECERRAAttorney General of CaliforniaJ.\.1ARGARITA P ADil.LASl,lpervising Deputy Attorney GeneralLAURAJ.ZUCKERMANDeputy Attorney GeneralState Bar No. 161896
1515 Clay Street, 20th Float .'P.O. Box 70550 Oakland, CA 94612-0550Telephone: (510) 879-1299Fax: (510) 622-2270 E-mail: [email protected]·
EXEMPT FROM FILING FEESGOVERNMENr CQDE § 6103
Attorneys for Plaintiff People of the State of California, ex rel. Barbara A. Lee, Director ofthe Department of Toxic Substances Control
SUPERIOR COURT OF TIIB STATE OF CALIFORNIA
COUNTY OF SACRAMENTO
PEOPLE OF THE STATE OFCALIFORNIA, ex reL Barbara A. Lee,-�{fu�;������NTOFTOXIC
Plairitiff,
v.
CALIFORNIA ELECTRONIC ASSETRECOVERY,
Defendant.
Case No. 34-2017-00217931
STIPULATION FOR ENTRY OF FINALJUDGMENT
Trial Date: None set.Action Filed: August 23, 2017
Plaintiff People of the State of California, ex rel: Barbara A Lee, Director of the
Department of Toxic Substances Control f'Plaintiff'' or "the Department"), and Defendant
California Electronic Asset R�very f'Defendant" or "CEAR'') enter into this Stipulation for
Entry of Final Judgment ("Stipulation''); and agree as follows:.
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!. GENERALBACKGROUND
CEAR is a recycler of electronic waste. CEAR operates a facility in Sacramento County
at 3678 Le May Street, Mather, California, 95655 ("the Facility"), and conducts other limited
activities at 10203 Missile Way, Mather, California, 95655 ("Missile Way''). At the Facility,
CEAR operates an indoor treatment machine known as the "MeWa Recycling Machine," which is·
used to shred electronic iievices ("EDs") and metal components into small pieces based on
cyclone action, and mechanically sort the processed pieces.· CEAR's universai and hazardous
waste resid� operations _at tlie Facility are regulated by the Department. In the Complaint filed ·
in this action, the.Department has alleged CEAR violated the Hazardous Waste Control Law,
H_ealth and Safety Code § § 25100 et seq. (the ''H:wCL") and its implementing regulations, Cal.
.Code Regs, tit. 22, Division 4.5, sections 66000 et seq. ("Title 22") at the Facility.
2. INVESTIGATION ACTIVITIES.·
On or about April 2:5, 2012, June 12, 2012, August 29, 2013,August.!4, 2014, August 27,
2015, and July 21, 2016, the Department inspected CEAR's Facility for compliance with the
HWCL and Title 22. On June 26, 2012, October 16, 2013, and August 28, 2014, the
Department issued CEAR inspection reports based on its ins�ons of the Facility. The
inspection rll?orts alleged violations of the HWCL and Title 22 stemming from the 2012, 2013,
and 2014 inspections of CEAR's Facility. The Department did not find any violations during its
2015. or 2016 inspections.
3. THE COMPLAINT.
The Department has filed a Complaint seeking, among other things, civil penalties against
CEAR pursuant to the HWCL and Title 22 based on the 2012, 2013, and 2014 inspections of the
Facility. the Department's Complaint alleges that CEAR violated multiple provisions of the
HWCL and Title 22.
4. SETTLEMENT OF DISPUTED CLAIMS.
This Stipulation for Entry of Final Judgment is not an admission by CEAR regarding any
issue of law oi: fact in the above-captioned matter or any alleged violation of any law. The
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STIPULATION FOR ENTRY OF FINAL JUDGMENT
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Department and CEAR ( collectively, the "Parties" and singularly, "Party") enter into the
Stipulation pursuant to a compromise and settlement. Each of the Parties consents to the entry by
the Superior Court of Sacramento County (the "Court'') of the Final Judgment in the substance
and form attached hereto as Exhibit A ("Final Judgment"). The Stipulation and Final Judgment
were negotiated and executed in good faith and at arms' length by each of the Parties, with their
respective counsel, to avoid expe�ive and protracted litigation regarding violations of the HWCL
and Title. 22 alleged by the Department in the Complaint, and to further the public interest. The
Parties have stipulated and consented to the entry of this Final Judgment without trial o�
adjudication of any fact or law herein. Nothing herein shall inure to the benefit of any persons
not Parties to this Stipulation.
5. JURISDICTION AND VENUE.
The Parties agree that the Court has subject matter jurisdiction over the matters alleged in
the Complaint and personal jurisdiction over CEAR. Venue is proper pu,suant. to Health & .-
Safety Code section 25183.
6. WAIVER OF TRIAL AND ENTRY OF JUDGMENT.
By signing and entep.ng into this Stipulation, CEAR waives its ·right to a hearing and trial
on �tters alleged in the Complaint and to appeal. Further, the Parties·each request entry of the
Judgment on the terms set forth in this Stipulation.
7. MAITERS COVERED BY THIS STIPULATION.
(a) Except as otherwise provided in this Stipulation, this Stipulation and the Final
Judgment entered thereon is a final and binding resolution and settlement solely of the HWCL
and Title 22 claims, violations, and causes of action that were o_r could have been alleged by the
· Department against CEAR in: (1) the Complaint, (2) the April 25, 2012, August 29, 2013,
September 11, 2013, and August 14, 2014 Summaries of Violations, (3) the 4:lspection reports
dated June 26, 2012, October 16, 2013, and August 28, 2014, and (4) the correspondence from
the Department to CEAR dated October 24; 2012, November 19, 2012, and March 25, 2013, on
the basis of facts known to the inspectors iis a result of their April 25, 2012, June 12, 2012,
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. STIPULATION FOR ENTRY OF FINAL JUDGMENT
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August 29, 2013, August 14, 2014, and August 27,201.5 inspections of the CEAR Facility and
Missile Way. The matt�rs described in the previous �entence are "Covered Matters." Any claim,
violation, or cause of action that is not a Covered Matter is' a "Reserved Claim." Reserved Claims
include, without limitation, any violation that occurs after the Effective Date of this Final
Judgment. . In any subsequent action that may be brought by the Department based on any claim,
violation, or �ause of a�tion that is not a Covered Matter pursuant to this Stipulation, CEAR
agrees that it will not assert that failing to pursue such claim, violation, or cause of action as. part
of this action constitutes claim-splittil)g.
(b) Except as provided herein, the Department covenants not.to sue CEAR, its
parents, subsidiaries, affiliates, a:ffiliate partnerships, predecessors, successors, shareholders,
partners, officers; directors, employees, cir agents,.for any Covered Matters in any judicial,
administrative, or regulatory.forum. The Department's covenant not to sue, solely withrespecpo
any Covered Matter, any of the above persons, parties, or entities is expressly conditioned upon
the express. �tten consent and acknowledgment by such persons, parties, and CI:1tities that they
are waiving their right, in accordance with the terms of Paragraph 7( d), to sue the Department,
any successor agency of the Dep!l!lment that may have responsibility for and jurisdiction over the
subject matter of the Stipulation or the Final Judgment, or any of their res�ve officers or
employees. CEAR's execution of the Stipulation filed in this action shall constitute such consent
and acknowledgment on behalf of CEAR, its parents, subsidiaries, affiliates, affiliate
partnerships, predecessors, successors, officers, directors, or employees, and CEAR represents
that the signatory to the Stipulation will bind them for purposes of the commitment in this
paragraph. The provisions of this paragraph become effective when the Final Judgment is 23 . entered, but cease to become effective in the event that CEAR fails to make timely payments in
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(c) Nothing in the Final Judgment shall constitute or be construed as a satisfaction or
release from liability for any conditions or claims arising as a result of past, current, or future
operatio� of CEAR, its parents, subsidiaries, affiliates, affiliate partnerships, predecessors in
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STIPULATION FOR ENTRY OF FINAL JUDGMENT
1 interest, successors, officers, directors, employees, or agents; except for the Covered Matters. 2 Toe Department reserves its right to initiate further actions pursuant to i� regulatory authority to 3 . protect public health or welfare or the environment on matters not within the scope of "Covered
4 Matters." 5 . (d) CEAR covenants not to pursue any civil or administrative claims against the 6 Department, against any successor agency of the Department that may have responsibility for and
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7 jurisdiction over the subject matter of the Stipulation or the Final ,Ju�gment, or against any of the 8 Department's officers or. employees, arising out of any Covered Matter (unless the Department9 pursues claims against CEAR, in which case CEARreserves all rights it lias to.assert any rights,.
10 . claims, and-defenses it may have). 11 (e) Paragraphs 7(a) and (b) do not limit the ability of the Department or any successor
12 . agency of the Department that may have 'responsibility for and jurisdiction over the subject m�tter 13 of the Stipulation or the Final Judgment to enforce the terms of this Stipulation or the Final 14 Judgment. 15 8. PARTIES BOUND.16 The provisions of this Stipulation and the Final Judgment shall apply to and· be. binding on
17 (I) CEAR and its s uccessors; and its officers, directors, and employees; and (2) the· Department18 · and any successor agency of the Department that may have responsibility for and jurisdiction19 over the subject matter of the Final Judgment. .20 9. NO WAIVER OF RIGHT TO ENFORCE.
21 The failure of the Department to enforce any provision of the Stipulation or Final_ 22 Judgment shall neither be deemed a waiver of such provision, nor in any way affect the validity 23 of the Final Judgment or the Department's enforce!I\ent authority. The failure of the Department 24 to enforce any such provision o_f this Stipulation or the Final Judgment shall not preclude it from 25 later enforcing the same or other provisions. No oral advice, guidance, suggestions, or comments 26 . by employees or officials of the Department or CEAR, or people or entities acting on behalf of 27
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STIPULATION FOR ENTRY OF FINAL JUbGMENT
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I CEAR, regarding matters covered in this Stipulation or the Final Judgment, shall be construed to 2 relieve CEAR of its obligations under this Stipulation or the Final Judgment.
.3 10. INJUNCTIVE REQUIREMENTS4 CEAR agrees to do the following with respect to its operations of the Facility:5 (a) CEAR shall accumulate all hazardous waste and universal waste in accordance6 with applicable accumulation times pursuant to California Code of Regulations, Title 22, sections· 7 .66262.34 and 66273.35, and CEAR shall accumulate all hazardous waste and universal waste in 8 · accordance with all applicable labeling and container requirements pursuant to California Code of 9 Regulations, Title 22, sections 6626231 through 66262.35 and 66273.33 through 66273.37.
10 (b) CEAR shall lawfully and timely dispose of or recycle all accumulated hazardous 11 waste at an authorized point. 12 (c) . C:EAR shall ensure that all iriversal waste treatment operations at the Facility13 meet the following requirements: 14 (i) CEAR shall maintain and operate the MeWa Recycling Machine at the15 Facility to minimize the possibility of unplanned, sudden, or non-sudden release of hazardous
. . 16 waste or hazardous waste constituents, as required by California Code of Regulations, Title 22,
17 section 66265 .31. 18 (ii) · In accordance with California Code of Regulations, Title 22, .section19 66273. 75, subdivision (a)(2), CEAR shall ensure that all niercury-colit/fining lamps, PCB 20 capacitors, and other components containing fluids (i.e., liquids or gases) that would be identified 21 as hazardous wastes are remoyed prior to undergoing treatment pursuant to treatment methods 22 that may.release the fluids, such as cutting, sawing, breaking, shredding, crushing, grinding, 23 ·Screening; sieving, acceleration, or compacting.24 (d) CEAR shall review, and if needed, modify its closure plan annually fa accordance
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(e) • CEAR shall use registered transporters and uniform manifests for hazardous waste
shipments, except as provided by Chapter 23 of the California Code of Regulations, Title.22.
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STIPULATION FOR ENTRY OF FINAL nJDGMENT
I (f) CEAR shall follow ali the hazardous waste export notification requirements of2 California Code of Regulations, Title 22; section 66262.53. 3 4 5 6 7 8
(g) CEAR'shall comply with the employee training requirements mandated by
California Code of Regulations, Title 22, section 66273 .36, J)ertaining to the management of universal waste EDs and/or cathode ray tubes (CRTs), CRT glass, or covered electronic waste,
including, but not limited to, the training of relevant full-time, part-time, and contract employees, and all managers responsible for Facility personnel that may manage or otherwise.come in contact with universal waste EDs and/or CRTs, CRT glass, ot covered electronic waste m the
9 · . scope of their work duties.· The training requirements shall not apply to persons· who are. exempt. 10 11 12
from training pursuant to section 66273.36, subsection (a)(2): CEAR shall maintain employee training records as required by these regulations.
(h) . In ord.er to minimize the possibility of the release of hazardous waste or hazardous.· 13 waste constituents from the Facility, CEAR shall conduct floor cleaning operations at the end of
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14 each shift in which universal waste is managed each day that it engages in universal waste 15 treatment activities; 16 (i) CEAR shall maintain the Me Wa Recycling.Machine in proper working order at all17 times. CEAR shall maintail). a log of maintenance activities perfoxmed on the M.eWA Recycling
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G) CEAR shall conduct 'weekly inspections of all areas of the Facility where universalwaste is generated or accumulated to inspect for improper management of universal and/or
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hazardous waste. CEAR shall maintain a log of such inspections and make the log available to the Department cir the Certified Unified Program Agency for review upon request.
Notwithstanding any other provision in this Stipulation, nothing in this Stipulation shallrelieve CEAR from complying with all applicable minimum standards set forth in Chapter 6:s of · Division 20 of the California Health and Safety Code and the regulations in Title 22 of theCalifornia Code of Regulations promulgated under that chapter.Ill
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STIPULATION FOR ENTRY OF FINAL JUDGMENT
11. MONETARY SETTLEMENT REQUIREMENTS.
CEAR shall pay the Department the sum of Three Hundred Ninety Thousand Dollars
($390,000), as and for civil penalties and costs. Of this amount, $298,342.37 is for penalties, and
$91,657.63 is for the Department’s costs. These payments shall be made as follows:
(a) Payment of $130,000 is due to the Department from CEAR within thirty (30) days of
entry of Final Judgment; and
(b) Four payments of $65,000 each are due to the Department from CEAR every 180
days thereafter.
If CEAR fails to make payment as provided above, CEAR agrees to pay interest at the rate
established pursuant to Code of Civil Procedure section 685.010, subdivision (a), on the amount
due and owing, and to pay all costs incurred by the Department in pursuing collection, including
attorneys’ fees.
All payments under the Final Judgment shall be made by cashier’s check, payable to the
Department of Toxic Substances Control, and sent by overnight mail to:
Cashier Accounting Office, MS-21A Department of Toxic Substances Control P.O. Box 806 Sacramento, CA 95812-0806.
The check shall bear on its face the phrase “DTSC # HWCA20146669 - CEAR.”
A photocopy of each payment made pursuant to the Final Judgment, including overnight
mail tracking information, shall be sent by e-mail or first-class U.S. mail, at the same time, to:
Sangat Kals Senior Environmental Scientist (Supervisory) Enforcement and Emergency Response Division Statewide Emergency Response and Sacramento Enforcement Branch Department of Toxic Substances Control 8810 Cal Center Drive Sacramento, California 95826-3200 Email: [email protected]
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Christopher Cho, Assist8l!t Chief Counsel Office of Legal C9unsel Department of Toxic Substances Control 100 l I Street P.O.Box 806 Sacramento, CA 95812-0806 E-mail: [email protected]
and.to:
LauraJ.Zuckennan Deputy Attorney General State of California Department of Justice Attomey General's Office 1515 'Clay Street, 20th Floor Oakland, CA 94612 .E-mail: [email protected]
12. NOTICE.
All submissions and notices required by the Stipulation and Final Judgment shall be in
writing, and shall be sent to:
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The Departm,:,nt:
SangatKals Senior Enyironmental Scientist (Supervisory) Enforcement and Emergency Response Division State'!Yide Emergency Response and S!!cramento Enforcement Branch bepartment of Toxic Substances Control 8 810 Cal Center Drive . Sacramento, California 95826-3200 Email: [email protected]
CEAR:
Paul Gao, Chief Executive Officer California Electronic Asset Recovery 3678 LeMay Street Mather, CA 95655-4117 Email: [email protected]
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STIPULATION FOR ENTRY OF FINAL JUDGMENT
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With simultaneous copy to counsel for CEAR: Ira J. Klein, Esq.
· Paul Hastings LLP101 California Street48thFloor·San Francisco, CA 94111Fax: (415) 856-7100Email: iraklein@paulhastings:com ·
All approvals and decisions regarding any matter requiring approvals or decisions under
the terms of this Stipulation and the Final Judgment shall be communicated in writing. Each
. Party ma y change its respective representative(s) for purposes of notice by providing the name
and address of the new representative, in writing, to all Parties. Any such change will be
effective seven (7) calendar days after the date of the written notice.
No advice, guidance, suggestions, or comments by employees or officials of the
Department tegard\ng submittals or notices shall be construed to relieve CEAR of i� obligation
to obtain any final written approvals required by the Final Judgment.
13. NOLIABILITYOFTHEDEPARTMENT.
Neither the Department nor any of the State of California's agencies, boarda, or
d�partments (collectively, "State.Entities") shall be liable for any injury or damage to persons or
,Property resulting from acts or omissions by CEAR, its directors, officers, employees, parent
companies, affiliates, agents, representatives, or contractors in carrying out activities pursuant.to
this Stipulation or the·Final Judgment, nor shall the Department or any of the State Entities be
held as a party to or guarantor of any contract entered into by CEAR, its directors, officers,
employees, agents, representatives, parent companies, affiliates, or contractors in carrying out the �
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requireµients of this Stipulation or the Final Judgment.
14. COMPLIANCE WITH APPLICABLE LAW.
CEAR shall implement the terms of the Final Judgment entered by the Court in this matter
in compliance with all local, State, and federal requirements, including, but not limited to,
requirements to obtain permits and to assure_ worker safety.
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15. ACCESS.10
· STIPULATION FOR ENTRY OJ: FINAL JUDGMENT
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Nothing in the Final Judgment is intended to !unit in any way the right of entry or inspection that the Department or any other agency may otherwise have by operation of any law.
16. INTEGRATION .. The Stipulation and the Final Judgment constitute the entire agreement and understanding
of the Parties with respect to .the entire subject matter hereof, and may not be amended or supplemented except as provided for in·this Stipulation or in the Final Judgment. No representations, oral ·or written, express or implied, other than those expressly set forth .. herein have been made by.any party hereto, No Other weements not specifically referred to herein, oral or written, shall be deemed to exist or to bind either of the Parties.
.17. AUTHORITYTOENTERSTIPULATION. Each signatory to the Stipulation certifies that he o.r she is fully authorized by the Party he
12 · or she represents to enter into this Stipulation, to execute it on behalf of the Party represented, and 13 to legally bind that Party. 14 18. MODIFICATION OF STIPULATION AND FINAL JUDGMENT.15 Neither the Stipulation nor the Final Judgment may be modified without written16 stipulation of the Parties hereto and approval by the Court. At any time after the Final Judgment 17 has been in effect for five (5) years, and CEAR has paid all amounts due hereunder, CEAR ma:y, 18 · · with notice to the Department, :fi)e a motion requesting that the Court order that tlj,e injunctive 19 20 21 22 23 24 25 26 27 28
requirements of Paragraph l O shall have no prospective force or effect based on CEAR's demonstrated history of compliance with the Fipal Judgment. Within thirty (30) days of the filing ofCEAR's motion, the Department may file a response in opposition. If the Department agrees that CEAR has complied. with the·obligations set forth in the Final Judgment, the Department IIU\Y file a statement ofnon-opp.osition to CEAR's motion, or file no response. Within :fifteen(15) days of any filing by the Department, CEAR may file a r esponse to the opposition, and the
: matter shall be set for hearing as soon as reasonably.possible thereafter. The Parties agree thatthe Court may grant CEAR's request upon determining thiit C:EAR has complied with theobligations set forth herein. The termination of the injunctive provisions of the Final Judgment
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STIPULATION FOR ENTRY OF FINAL ruDGMENT
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1 shall have no effect on CEAR's obligation to comply with the requirements imposed by statute, 2 · regulation, ordinance, or law .
. 3 19. EFFECT OF STIPULATION AND FINAL JUDGMENT.4 Except as provided in Paragraph 7(a), nothing herein or in the Final Judgment is intended,5 nor shall it be construed, to preclude the Depll!'fment, �r any state, county, or local agency, 6 . department, board, or entity, or any Certified Unified Program Agency, from taking appropriate· 7 enforcement action or otherwise exercising its authority under.any law, statute, or regulation. 8 20. GOVERNINGLAW.9 The terms of the Final Judgment shall be governed by the laws ofthf! State of California.
10 21. RETENTION OF JURISDICTION.11 The Parties agree that the Court has continuing jurisdiction to intei:pret and enforce the 12 .. provisions of this Stipulation and the Final Judgment. 13 22. EQUAL AUTHORSIDP.14 This Stipuiation and the Final Judgment shall be deemed to have been drafted equally by 15 all Parties hereto: The Parties agree that the rule of construction holding that ambiguity is 16 · construed against the drafting party shall not apply to the interpretation of this Stipulation or the 17 Final Judgment. . 18 23. COUNTERPARTS.19 The Stipulation may be �xecuted in several· counterparts, each of which shall be deemed20 an original, and all such counterparts taken together shall constitute an integrated document 21 facsimile signature and PDF signatures shall be deemed original for the purposes of this 22 Stipulation. 23 24. ENTRY OF JUDGMENT PURSUANT TO STIPULATION.24 The Parties further stipulate that upon approval of this Stipul_ation by the Court, the Court25 shall enter the Final Judgment in this matter in the form set forth in the attached Exhibit A. The 26 . effe�tive date of this Stipulation is the date this Stipulation is filed with the Court. The effective 27
28 date of the Final Judgment is the date the Final Judgment is entered by the. Court. If the Court
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STIPULATION FOR ENTRY OF FINAL JUDGMENT
1 does not approve this S.tipulation and the Final Judgment in the form and substance proposed in
2 Exhibit A hereto, each party reserves the right to withdraw both the Stipulation and the Final
3 Judgment upon written notice to all Parties and the Court.
4 IT IS SO STIPULATED:
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Dated: 2017-----�
Dated:�'. l-6,2011
.15 APPRQVEDASTOFORM:
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Dated: ___ _,____,2017
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0
0K2013508821
,2017
By.
By:
PEOPLE OF lHE S'J7AIE OF CALIFORNIA, ex rel.Barbara A Lee, Director of the DEPARTMENT OF
. TOXIC S.UBSTANCES CONTROL
DENISE TSUJI, BRANCH CHIEF · ENFQRCEMENT ANO EMERGENCY.REsl'oNsE
DIVISION
CALIFORNIA ELEC'IRONIC AsSET RE.COVERY.
OFFICER
XAVIER BECERRA Attorney General of California MARGARITA PADILLA. Supervising Deputy Attorney General
By:
· LAURAJ.ZUCKERMANDeputy Attotney GeneralAttorneys for Plaintiff People of the State ofCalifornia ex rel. Barbara A. Lee, Director of theDepart,nent of Toxic Substances Control .
PAULHAsnNGsLLP
·ff.�IRAJ.KiEJN . z . Attorneysfor/)efl . aAR . ..
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. · STI!'uLATION FOR ENTRY OF FINAL JUDGMENT
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does not approve this Stipulation and the Final Jud!µllent in the form and substance proposed in
Exhibit A hereto, (\ach party reserves the right to withdraw both the Stipulation and th.e Final
Judgment upon written notice to all Parties and the Court.
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iT IS SO STIP�TED:
?-t;, ,2017
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13 Datcd: _____ �2017
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15 APPROVED AS TO FORM:
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25 . Dated: ____ �2017
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0K20I350882l
By:
By:
By:
PEOPLE OFIBE STATE OF CALIFORNIA, ex r�l. Barbara A. Lee, Director of the DEPARTMENT OFTOXIC SUBSTANCES CoN'fROL
ENFORCEMENT AND EMERGENCY REsPONSE DMSION
, CALIFORNIA.�ONICASSETREcoVER.Y.
. PAUL GAo; CHIEF ExECUTIVll 0FF1CER
XAVIER 8BCERRA Attorney General of CaliforniaMARGARITA PADILLA Supervismg Deputy Attorney General.
PAULIIAsTINGS LLP
!RAJ.KLEIN Attorneys for Defendant GEAR
13
STIPULATION FOR ENTRY OF FINAL .TUOOMENT
