FILED Superior Cu.lrt cf Caifttria

C.Ounty of Los Angeles

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XAvmR BECERRAAttomey General of the State of California DAVID ZONANA Sl1pervising Deputy Attorney GeneralANDREW WmNER, State Bar No, 282414Deputy Attorney General

1515 Clay Street, 20th Flom' •P..O. Box 70550 Oakland, CA 94612-0550 Telephone: (510) 879-1975 Fax: (510) 622-2270Emui1: Andrew.Wiener@doj.ca.gov

Attorneys for the People ofthe Stale ofCallfo.rn.ia., ex rel. Meredith J. Williams, ActingDirecto,~ California D-epcmment ofToxtcSubstances Control

. EXEMPT FROM FILING FEES GOVERNMENT CODE§ 6103

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

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PEOPLE O1<'1'HE STA'I'E OF CALIFORNIA, ex rel. MEREDITH .J, WILLIAMS, ACTING DIRECTOR,CALIFORNIA DEPARTMENT OF TOXIC SUDS'fANCES CONTROL,

Plaintiff,

v.

CHARLES COMPANY; CORSAIR LLC;and ADVANCED GEO ENGINEERING INC.,

Defendants.

Case No. JI~ STC\I i•q 'K ii

STIPULATION FOR ENTRY OF JUDGMENT AND PElUVTANENT INJONC'l'ION ON CONSENT

(Code of Civ. Proc.§ 664.6)

· Plaintiff, the People of the State of CaBfomia, ex rel. Meredith J, Wi1limns, Acti1ig

Director, California Department of Toxic Substances Control ("DTSC"), and Defendants

Charles Company and Corsa.it' LLC (collectively "Charles Company") entel' into this

Stipulation fo1· Entry of Judgment and Permanent Injttnction 011 Consent ("Stipulation") and

stipulate as follows. Plaintiff has entered into a separate settlement with Advanced

Stipulndon for Entry of Judgment an(l PcmnnuentIt\lunctlon on Consent [Case No. J l°ls1c.v,1,-it1

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GeoEngineel'ing, Inc. ·

A. THE COMPLAINT AND INTRODUCTION

1, DTSC filed this enforcement action against Charles Company, among

others, for Permanent Injnnction, Civil Penalties, and Other Equitable Relief ("Complainn

under the California Hazal'dous Waste Control Law, Health and Safoty Code section 25100ttttt

et seq., ("HWCL") and its implementing mgulations, California Code of Regulations, title

22, division 4.5, section 66260J, et seq. ("Title 2211) in connection with the former Horncio

M. Luna Gun Club ("Gun Club") located on south of West Second Street nem· U1e Animalttttt

Shelte1· Ddve intersection in the City of Calexico, in the State of California. Charles

Company was contracted by the Calexico Community Redevelopment Agency (the

"Redevelopment Agency") to remediate and redevelop the Gun Club,

2.ttttt On or about January 22. 2013, DTSC1s Certified Unified Progmm Agencyttttt

for Impei:ial County ("Imperial CUPA") receJved a _complaint from the Allied hnpedal

Class HI Landfill in'rmpel'iul County, California ("Allied Imperial Landfill") that it had

received truckloads of contaminated soil hazardous waste from the �hm Club ("Landfill

Complaint").

3. DTSC investigated the Landfill Complaint and determined that Charlesttttt

Company (through consultants and contrnctors) had taken four truckloads of contaminated

soil from the Gun Club to the Allled Impedal Lanctfill on or about January 21 and Janua'.l'y

22, 2013, DTSC further detennined that the soil contained bullets and bullet fragments ai1d

was a Resource Conservation and Recovery Act (RCRA) and non,RCRA lead hazardous

waste, The hazru:dous waste soil was later removed from the Allied Imperial Landfill and

sent to a facility p1'opedy equipped and permitted to 1·eceive hazardous waste. DTSC

identified numerous violations of the HWCL by Charles Company, an�ong others.

4. As set out rool'e fully in tlie Complaint filed in this action, DTSC alleges thatttttt

Charles Company violated the HWCL and Title 22 by: delivexing haza1'dous waste and

disposing or causing the disposal of. hazardous waste at a point not authorized to receive.

hazardous waste; failing to complete hazardous waste manifests and transporting hazardous 2

Stpulation for Entry of Judgment and Permanent InJtmction on Consent [Cuse No. ]. \ � �Tl V f q � I\

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Stipulation for Entry of Judgment 11ncl Penmment Ittjnnctlon on Consent [Case No. ' ]\ q c;T l V I� ,g II I­

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waste without 1Iianifests; tmnsferring custody of hazmdous waste to transporter(s) who didttttt

not hold valid registrations; offering hazardous waste to transporte1·(s) that had not receive d

identification numbers from DTSC or the United States Environmental Protection Agency;

and storing hazardous waste without a hazardous waste pe1mit or other authorization from

DTSC.

B, AGREEMENT TO SETTLE DISPUTE

5. DTSC and Chfrrles Company, collectively "the Pru'ties," entel' into thisttttt

Stipulation pursuant to a compromise and settlement and mutually consent to the entry by

the Superio1·. Court of the State of California for the County of Los Ang eles ("Court") of the

agreed upon Judgment on Consent and Permanent Injunction ("Judgment"), whi�h is .

lodged concurrently with this Stipulation. A copy of the pl'oposed Judgment is attached to

this Stipulation as Exhibit 1. The Patties are each represented by counsel. The Office of

the Atto1;ney Gene1·al of California l'epresents Plaintiff and P.C. Law Group tepresents

Charles Company. This Stipulation and Judgment were negotiated in good faith and at

artns i length by the Parties to avoid expensive and protrncted liHgation regarding the

alleged violations of the HWCL and Title 22 and to'further the public,interest,

C. JURISDICTION AND VENUE

6.ttttt The Parties agree and hereby stipulate that for purposes of this Stipulationttttt

and the .Tudgrnent; the ColU't has subject matter jurisdiction over the matte1·s alleged in the

Complaint, personalj�1risdiction over the Patties, and that venue in this Court is prope1·

under Health and Safety Code sections 25181 and 25183.

D, WAIVER OF HEARING AND TRIAL AND ENTRY OF .JUDGMENT ' .

7.ttttt By signing and entedng into this Stipulation, Charles Company waives itsttttt

right to a hearing and trial on the matters alleged J.n the Complaint and waives its right to

appeal. Ill

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E, APPLICABILITY

8.oooooThis Stipulation and the Judgn�ent shall apply to: (1) DTSC and any successorooooo

agency, and (2) Chades Company, and its officers, directors, managers, employees, agents,

contractors, representatives, and any successorn and assigns in their official capacity.

F. DEFINITIONS

9; Except where othe1wise expressly defined herein, all terms in this

Stipulation shall be interpreted as set fo1'th i1!, , and consistent with, the HWCL and Title 22,

G. CIVIL P'ENALTIES .

10.ooooCharles Company shall pay DTSC a total of one hundred and nineteenooooo

thousand clollm·s ($119,000) in civil penalties as set :forth herein.

1, SET'l'LEMENT PAYMENTS

11.ooooWithin thil:ty (30) calendar days of entry of the Judgment in this matter,ooooo

Chades Company shall pay to DTSC an initial sum of nineteen thousand eight hundred andooooo

thfrty�thi-ee dollars and thirty-four cents ($ l 9,833.34) (!'Initial. Settlement Payment''.),

Chades Company shall also pay to DTSC eleven (11) monthly payments totaling thirty�six

thousand one hundred and sixty-six dollars and sixty-six cents ($36,l.66.6.6) ("Monthly

Payment").The first Monthly Payment in the amount of tlu·ee thousand six hundred and six

dollars and six cents ($3,606.06) shall be due on the first day of the month after DTSC.

receives Chades Company's 'Initial Settlement Payment .. Thereafter, Chm'les Company

shaU make a Monthly Payment in the amount of three t11ousat1d six huncb:ed and six dollars

and six cents ($3,606.06) by the fkst day of each month for the next ten (10) months until

siich th'.ne as it has made cash payments totaling $59,500,

12, The Xniti�l Settlement Payment and the Monthly Payments may be made by

electronic fund.s transfer as set forth in Exhibit 2 or by cashier's check. If paid by cashier's

check, the cashiel'' s check shall be made payable to "the Department of Toxic Substances

Control," and sent via certified mail to:

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Stipulation for Entry of Judgment and Permnnent In.Junction on Coi1sent [Cnse No. ]· \ � S1lv 10\'t I\.

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Cashier Accounting Office Department of Toxic Substances Cont:.t'ol P.O. Box 806 Sacramento, CA 9581.2-0806

The check for the Initial Settlement Payment and each Monthly Payment shall bear the

name of this case and the court number, The Initial Settlement Payment and each Monthly

Payment shall be accompanied by the Payment Vouche1' that is attached to this Stipulation as

Exhibit 3. An electronic (e.g., Adobe PDF) copy or paper photocopy of the Initial Settlement

Payment and each Monthly Payment shall be sent, at the same time, to those persons ickmtified in

Paragl'aph L(l)(a).

13.yyyyCharles Company shall also fund thl'ee supplemental environmental projectsyyyyy

(HSEPs") with a cumulative value o:f $59,500. The SEPs shall include the following:

a.yyTwo California Compliance School trainings: Cha:des Company shall expend te11yyyyy

thousand dollars ($10,000) for each tta:lning. The first training shall be fundedyyyyy

with ten thousand dollars ($10,000) within 12 months of entry of the Judgment inyyyyy

this matter and the second tt'aining shall be ftmded with ten thousand ($10,000)yyyyy

. within 24 months of ent1·y of the Judgment in this matter. The checks shall beyyyyy

made out to "Kern Community College District/ CCS!l and shall be mailed toyyyyy

2100 21st Street, Bakersfield, CA, 93301, Attn: Richard M, Casagrande. A

notation on the checks shall be made to the Case Number assigned to this mattel'yyyyy

by the Comt.

·yb, Fund Impe1fal County Ffre Department hazardous materials equipment pmchases:yyyyy

Charles Company shall pay the Impedal County Fire Department Revenue

Account 1f1501001 thirty-nine thousand five hundred dollars ($39,500) within

sixty (60) calendar days. of entry of the .Judgment in this matter. The payment

shall be made by check. The check shall be made out to. "Impel'ial County Fke

Department" and shall be m.ailed to 2514 La Bmcher.ie Road, Imperial, CA

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Stipulation for Entry of Judgment and Permanent Injunction on Consent [Case No. ]

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92251, Attn: Kim Laullin. A notation on the check shall be made to the Case

Number assigned to this matter by the Court.

14.nnnnyVithin thirty (30) calendar days of comp�eting each SEP (Le., making thennnnn

required payments), Chru:les Company sh�tll submit a copy of each check used to fund the

SEP to those persons identified in Parngraph L(l)(a).

15.nnn In recogniti01i of the beMfits of these SEPs to protecting public health andnnnnn

the environment, $59,500 of the �enalty for the violations identified in the Complaint has

been suspended pending Charles Company satisfactorily completing the SEPs. If Charles

Compai�y fails to complete the SEPs within the required timeframes identified above,

Chades Company shall pay the balance of the SBP(s) amount not expended to DTSC as

civil penalties. Upon proof that Charles Com1)any has completed the SEPs within the

required timefrru:nes identified above, $59,500 of the penalty for the violations identified in

the Comphtint shall be pel'manently suspended.

2, LATE PAYMEN'rS, POST JUDGMENT INTEREST and ENFORCEMENT

of JUDGMENT COSTS

nnn . 16. Charles Company shall pay a late payment of three hundl'ed doilars ($300)nnnnn

pe1· day f01: each day the Initial Settlement Payment, any Monthly Payment, ot· any SEP

payment is lace. In addition, Charles Company shall pay DTSC posHudgmentinterest as

provide<.� in Code of Civil Procedtu·e section 685,010 (10 percent) fror1.1 any date of default.·nnnnn

Pt1rt:he1\ Charles Company is obligated to pay costs incurred by DTSC in enforcing the

mo11ey judgment against Charles Company, in this matter, including, but not limited to

1'eason�ble attorneys' fees.

H.nnnINJUNCTIVE RELIEFnnnnnCharles Company, shall be, and is pel'manently en.joined as follows:nnnnn

17.nnnnPnrsuan:t to the provisions of Health and Safety Code sections 25181 andnnnnn

25184, Charles Company shall comply with the HW�L and Title 22 at and in connectio11

with its operations.

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Stipulntlon for Entr'Y of Judgment and Permanent l1tju11ctla11 on Consent [Cuse No', ]

l��TlvJei;�II

1 18.ooooIn connection with its operations, Charles Company shall comply withooooo

2 Health and Safety Code section 25189 .2 and California Code of Regulations, Title 22, ·ooooo

3 section 66263.23, which provide that it is illegal for a pel'son to dispose, or cause the

4 . disposal of, a hazal.'�ous waste at a point not authorized to receive such waste.

5 19.ooooIn connection with its operations, Charles Compai1y shall comply withooooo

6 Health and Safety Code section 2,5203 1 which provides that it is illegal for any pel'son to

7 dispose of a hazardous waste except at a disposal site or facility of an owner 01· operator

8 who holds a valid hazmdous waste facilities permit Ol' other grant of authol'ization·from

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1.0 20.ooooIn connection with its operations,. Charles Company shall comply withooooo

11 Health and Safety Code section 25160, which pl'ovicles that any person generatingooooo

12 haza.l'dous waste that is transported, or submitted for transpol'tation, for offsite hanclling

13 shall complete a manifest prior to the time the waste is transported or offered for

14 transpol'tation and that any pe1·so1� who transpol'ts hazardous waste in a vehicle must have a

15 manifest in his or her possession while transporting the hazardous waste.

16 21, ln connectlon .with its operations, Charles Company sh�ll comply with

17 Health and Safety Code section 25163, which l'equit'es any person engaging in the

18 transportation of hazardous waste to hold a valid registration issued by DTSC, provides that

19 it is unl�wful fo1· any person to transfer custody of hazardous waste to a transporter who

20 does not hold valid registra:tioni and l'equil'es Umt any petson who transports hazardous

21 waste in a vehicle must have valid registration in his or her possession while trnr1sporting

22 hazardous waste.

23 22.ooooIn connection with its operations, Chades Company shall comply withooooo

24 Health and Safety Code section 66262.1.2, which provides that a generatol' shall not offel'

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23.ooo In connection with its operations, Charles Company shall comply withooooo

Health and Safety Code section 25201 i which provides that no owner or operator of a

storage facility shall store hazardous waste unless the owner or ope1·ator holds a hazardous

waste facilities permit or other grant of authodzntion from DTSC.

I. ENFORCEMENT OF CONSEN'r JU))GMENT

24.ooooDTSC has the right to enforce this Stipulation and the Judgment as providedooooo

hf.?rl'.lln and pursuant to applicable law,

25.ooooChades Company reserves all rights to oppos? any motion brought by DTSCooooo

to ·enforce any provi sion of the Judgment, ·

26.ooooNothing in the forgoing is intended to, nor shall be construed to, resti'ictooooo

DTSC' s authority to pu1'sue a new action under the HWCL and or Title 22 against Chades

Company and to seek injunctive relief and penalties, except as provided below in

Section K, ''Matters Covel'ed and Reserved Claims/'

27.ooo· By filing and serving a regulady noticed motion in accordance with Code ofooooo

Civil Procedm·e section 1005, DTSC·rnay move this Court to e;,nforce any provision of the

Judgment and to awaed other appl'op.l'l.ate relief, including penalties for contempt, additional

pennltles consistent with the provislom of the Judgment or the prnvisions of the HWCL.

J. EFFECT OF CONSENT JUDGMEN'ti

28.ooooOther than "Covered Matters" as defined in Paragraph 29 below, nothingooooo

herein is intended., nor shall it be construed, to preclude DTSC, or any state, county, or .

local .

agency, departm:ei1t, board, or entity from f.?xemising its author.tty under any law, statut0, or

regulation,

K. MATTERS COVERED AND RESERVED CLAIMS

29, This Stipulation 'tmd the Judgment entered in this matter is a final and

binding resolution and settlement of the violations specifically alleged by DTSC against

Charles Company in th!=) Complaint. The matters descl'lbed in. the pl'evious sentence are

"Covel'ed Matte�·s." DTSC reserves its authority to purnue any claim, violation, or cause of

action that is not a Covered Matter (''Reserved Claims"). Any claim, violafion, or cause of

Stlpulati�n for Entry of Judgi.;ent and Pormanent lnjunctlon on Consent [Cas� No, ]\� s·rc v 1 !\4.1 I

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action that is not within Covered Matters is a Reserved Claim. Nothing herein shall be

interpreted to limit or restrict any. claims that DTSC may assert against any independent

contractor or subcontractols of Chades Company; DTSC rese!'ves the right to pursue .any

Reserved Claim1 and Charles Company reserves the right to assert any and all other

defenses to any Reserved Claim.

30.eeeeeIn any subsequent action that may be brought by DTSC based on anyeeeee

Reserved. Claim, Charles Company agrees that it will not assert that 'failing to pm·sue such

Reserved Claim as part of this action constitutes claim-splitting,

31; Chades Company covenants not to pursue any civil or administmtive claims

against DTSC or against any agency of the State of California, arlsing out of or related �o

any Covel'ed Matter; provided, howevet\ that if any agency initiates claims against Charles .

Company that ai·e independent of the claims asserted in this action, Chades Company

reserves any and all dghts, claims, demands, and defenses against such agency.

L, NOTICE

32.eeeeeAll submissions and notices required by this Stipulation shall be sent to:eeeee

a.eeFo1· Plaintiff:eeeee

Robert Krug Supervisot/S.eniot· Environmental Scientist Department of Toxic Substances Control 627 W uke A venue Bl Centeo, CA 92243 Email:eRQJ)ert,K1.JJg@dt�Q,Qi1,gov

With a copy to:

Brooke O'Hanley Selzer, Senior AttorneyeeeeOffice of Legal Counsel Department of Toxic Substances Control 700 Heinz A venue Bel'keley, CA 947:10-2721 Email: B1:09ke,S9]z&r@dt��eee

and

Andrew Wiener Deputy Attorney Genen1l Office of the Attorney General

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1515 Clay Street, 20th Floor Oaldand, CA 94612·0550 Email: Anru.·i'l:�. Wienet@dQL&'\,gQY

b, For Chades Company:

Made Gabay The Charles Company 9034 W. Sunset Blvd. West Hollywood, CA 90069 Email: �\ii>charl9s"co1Ullli!))'.,CO.!Jleeee

With a copy to:

Patricia .T. Chen PC Law Group 2 Park Plaza, Suite 480 Irvine, CA 92614 Email:ev.gJlen@pclawgrp.com

l 33.eeeeEach Patiy may chru1ge its r�spective representative(s) fot purposes of noticeeeeee

by providing the name and address of the new representative, in writing by certified mail, to

those persons identified in Paragraph 32. The change shall be effective upon receipt of the

certified mail.

M, NECESSITY FOR WRITTEN APPROVALS

34.eeeeAll notices, approvals, and decisions of DTSC under the terms of thiseeeee

Stipulation or the Judgment shall be communicated to Charles Company in wl'iting. No

oral advice, guidance, suggesti.ons, or oormnents by employees 01· officials of DTSC

regarding submissions 01· notices shall be consttu�d to relieve Chal'les Company of its

obligations to obtain any final written approval requil'ed by this Stipulation o'L' the

Judgment.

N, NO LIABILITY OFDTSC

35, DTSC shall not be Hable for any il\Jnry or damage to persons orpr(?pe1'ty

resulting from acts or omissions by Charles Company or its tespective officers, directors,

employees, agents, repi·esentatives, contractors, successors, or assigns, acting in concert or .

participating with Chai'les Group in carl'ying out activities pursuant to the Judgment, nor

shall DTSC be held as a party to. 01· guarnntor of any contract entered into by Charles

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Stiplllution fox Entry of Judgment and Permanent I1�unotlon 011 Consent [Cnse No. ],,�1cv 1'1'?.>l\

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Company 01· its respective officers, directors, employees, agents, representatives,

contractol's, successors, or assigns, acting in concert or participating with Charles Group in

carl'ying out the 1·equirements of this Stipulation or the Judgment..

o. NO WAIVER OF RIGHT TO ENFORCEttttt

36.ttttt The failure of DTSC to enforce any provision of this Stipulation or thettttt

Judgment shall neither be deemed a waiver of such. provision, nor in any way affect the

validity of this Stipulation or the Judgment. The failure of DTSC to enforce any such

provision shall not preclude it from latel' enforcing the same 01· other pmvision of thi�

Stipulation or the Judgment. No oral advice) guidance, suggestions, or comments by

employees or officials of DTSC regmding matters covered in this Stipulation or the

Judgment shall be constrned to relieve Charles Company of its obligations under this

Stipulation qr the Judgment.

P.tttttFUTURE REGULATORY CHANGES ttttt

37.ttttt Nothing in this Stipulation or the Judgment shall excuse Chlll:·les Companyttttt

from meeting any more stdngent requirements that may be imposed by changes in

applicable. law in the future.

Q, AUTHORITY TO ENTER I'NTO STIPULATION

38.ttttt Bach signatory to this Stipulation certifies that he or she is fully authorizedttttt

by the ·pmty he or she represents to enter into this Stipulation, to execute it on behalf of the

ttparty represented, and to legally bind that party.

R.ttttt CON'I'INl1ING JURISDICTIONttttt

39.ttttt The Parties agree that this Court has continuing jurisdiction to interpret andttttt

enforce this Stipulation and the Judgment. The Court shall retain continningjm'isdiction to

enforce the terms of this Stipulation nncl the Judgment and to address any other matters

arising out of or rngarcing this Stipulation and the Judgment.

s. INTERPRETATJON OF STIPULATION AND JUDGMENTttttt

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Stipulation for Enti·y of Judgment nnd Permanent Iitjunction on Consont [Case No, J

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40.eeeeThis Stipulation and Judgment shall be deemed to have been drafted equallyeeeee

by the Parties hereto. DTSC and Charles Company agl'ee that the rnle of construction

holding that ambiguity is construed against the drafting party shall not apply to the

interpretation of this Sti�ulation and the Judgment.

T. JUDGMENT PURSUANT TO STIPULATION

41.eeeePursuant to Code of Civil Procednre section 664.6 1 the Parties furthereeeee

stipulate that upon approval of this Stlpnlation by the Court, the Coutt may enter Judgment

in this matter in the form set forth in the attached Exhibit 1. If the Court does not approve

this Stipulation and the agrned upon Judgment in the form and substance proposed in

Exhibit 1 hereto, each Pn:rty reserves the light to 'withdraw both the Stipulation and the

proposed Judgement, upon written notice to all Pmties and the Court,

U, COUNTERJ>ARTSIGNATURES

42.eeeeThis Stipulation may be executed in. severnl counterpart originals, each of·eeeee

which taken together shall constitute an integrated document,

V, INTEGRATION

43.eeeeThis Stipulation and the Judgment constitutes the entire agreement betweeneeeee

DTSC and Cha.des Company with respect to the Covered Matters and may not be amended

or sup1Jlemented except as provided fot· in this Stipulation or the Jndginent. No oral

representations have been made or relied on other than as expressly set forth herein.

W, MODIFICATION OF JUDGMEN'l'

44.eeeeThis Stipulation and the Final Judgment may be amended or supplementedeeeee

only pmsuant to a written ag1'eement signed by the Parties, followed by written approval by

the· Court, or by order of the Cotll't following the filing of a duly noticed motion.

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x; COSTS AND ATTORNEYS' FEES

45.sssssExcept as otherwise provided in this Stipulation and the Judgment, eachsssss

Party tq this Stipttlation and the Judgment shall bear its own costs and attorneys' fees;

IT IS SO STIPULATED

Plahltiff, PEOPLE OF THE STA TE OF CALIFORNIA, ex rel. Merel!ith.J, Williams, Acting Director, California Depai·trnent of Toxic Substances Control

DATED:�

By: Signature on File Keith K.iharn, Chie

, Enforcementand Emergency Response Divisiprt Hazardous Waste Management Program Plaintiff People of the State of' Califomi!\, :e:xJ,el, Mi;li'eclith J. Williams, Acting Director, Califomia

· Department of Toxic Substances Co:n:,trQ1sssss

Chades Company

Signature on Filesss

Mark GabayCharles Company and Corsail' LLC

Title: President

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Stipulation for Ent1·y of Judgment and Permanentlnjunction on Consent[CaseNo.

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Approved as~ fo1·m by:

PCLaw Gl'oup

B tricla J. Chen ttorney for The Chaties Company and Corsair lLC

Date: _li---+-/~...........,_/1 ........ 1 _ I

XAVIER BECERRA Attorney Gener.al of Californi;1

David Zonana Supervisii,g Deputy Attomey General

n rewWWner Deputy AtbJmey General

Date: _b /{,// 9 -SD2014.S12485 91035464.docx

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Stipulation for Burry of Judgment and Permanent lnjunctloi1 on Conient [Case No J

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Signature on File

Signature on File

EXHIBIT 1

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XAVIER BECERRA

Attorney General of the State of California DAVID ZONANA

Supervising Deputy Attorney General ANDREW WIENER, State Bar No. 282414 Deputy Attorneys General

1515 Clay Street, 20th Floor P.O. Box 70550 Oakland, CA 94612-0550 Telephone: (510) 879-1975 Fax: (510) 622-2270 Email: Andrew.Wiener@doj.ca.gov

Attorneys for Plaintiff, People of the State of · California, ex rel. Meredith J. Williams, ActingDirector, California Department of Toxic Substances Control

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

PEOPLE OF THE STATEOF CALIFORNIA, ex rel. MEREDITH J. WILLIAMS, ACTING DIRECTOR, CALIFORNIA DEPARTMENT OF TOXIC SUBSTANCES CONTROL,

Plaintiff, v.

Case No. I� �r C V I � � I I

[PROPOSED]JUDGMENT AND PERMANENT INJUNCTION ON CONSENT

CHARLES COMPANY; 'CORSAIR LLC; and ADV AN CED GEOENGINEERING,

Defendant.

Having reviewed the Stipulation for Entry of Order and Judgment on Consent (the

"Stipulation") executed by Plaintiff the People of the State of California, ex rel. Meredith J.

Williams, Acting Director, California Department of Toxic Substances Control ("DTSC') and

Defendants Charles Company and Corsair. LLC ( collectively "Charles Company"), and good

cause appearing herein, the Court finds that the settlement between the Plaintiff and the

Defendants as set forth in the Stipulation is fair and in the public interest and approves the

Stipulation.

·

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{PropoS'ed] Judgment and Permanent Injunction on Consent [CASE NO. --�,

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Accordingly, the Court enters this Judgment on Consent on the terms set forth in the

Stipulation.

IT IS SO ORDERED AND ADJUDGED.

DATED: HON. JUDGE OF TIIE SUPERIOR COURT

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[Proposed] Consent Judgment and Permanent Injunction [CASE NO. ]\l)S"fG\/t°loiil