1 GREGORY D. TOTTEN 

District Attorney, County of Ventura 

2 MITCHELL F. DISNEY, State Bar No. 138114 

Senior Deputy District Attorney 

3 5720 Ralston Street, Suite 300 1. 

VeNTURA 

SUPERIOR COURT 

FILED 

Ventura, CA 93003 

4 Telephone (805) 662-1706 APR l 2 20i2 APR 1 6 2012 

5 Attorneys for Plaintiff, People ofthe State of 

California 

MICHAEL D. PLANET 

Executive OHicer and Clerk 

BY,: , Deputy 

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[Plaintiff's Counsel Continued on Attached] MARTHA MClAUGHLIN 

SUPERIOR COURT OF THE STATE OF CALIFORNIA 

COUNTY OF VENTURA 

PEOPLE OF THE STATE OF Case No. 56-2012-00415450-CU-MC-VT A 

13 CALIFORNIA, 

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v. 

CVS PHARMACY, INC., 

STIPULATION FOR ENTRY OF FINAL 

Plaintiff, JUDGMENT AND PERMANENT 

INJUNCTION 

Action Filed: 

Defendant. 

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Additional Counsel for the P laintif.f 

NANCY E. O'MALLEY 

District Attorney of Alameda County 

KENNETH A. MIFSUD, SBN 144000 

Senior Deputy District Attorney 

Consumer and Environmental Protection Division 

7677 Oakport Street, Suite 650 

Oakland, CA 94621-1934 

Telephone: (510) 569-8816 

TODD D. RIEBE 

District Attorney of Amador County 

708 Court Street, Suite 202 

Jackson, CA 95642 

Telephone: (209) 223-6444 

MICHAEL L. RAMSEY 

District Attorney of Butte County 

25 County Center Drive, Suite 245 

Oroville, CA 95965-3370 

Telephone: (530) 538-7411 

BARBARA M. YOOK 

District Attorney Calaveras County 

Government Center 

891 Mountain Ranch Road 

San Andreas, CA 95249 

Telephone: (209) 754-6330 

MARK A. PETERSON 

District Attorney of Contra Costa County 

STACEY GRASSINI, SBN 154937 

Deputy District Attorney 

900 Ward Street 

P.O. Box 670 

Martinez, CA 94553-0150 

Telephone: (925) 957-8604 

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EDWARD S. BERBERIAN, JR. 

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District Attorney of Marin County 

ANDRES H. PEREZ, SBN 186219 

3 Deputy District Attorney 

Hall of Justice 

4 3501 Civic Center Drive, Room 130 

San Rafael, CA 94903 

5 Telephone: (415) 499-6450 

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7 C. DAVID EYSTER 

District Attorney of Mendocino County 

8 100 N. State Street, Room G-10 

Ukiah, CA 95482 

9 Telephone: (707) 463-4211 

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11 LARRY D. MORSE 

District Attorney of Merced County 

12 2222 M. Street 

Merced, CA 95340 

13 Telephone: (209) 385-7383 

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15 DEAN D. FLIPPO 

District Attorney of Monterey County 

16 ANNE M. MICHAELS, SBN 136134 

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Managing Deputy District Attorney 

DUE NDREU, SBN 251278 

18 Deputy District Attorney 

1200 Aguajito Road, Room 301 

19 Monterey, CA 93940 

Telephone: (831) 647-7770 

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21 GARY LIEBERSTEIN 

22 District Attorney of Napa County 

CATHERINE C. BORSETTO, SBN 176337 

23 Deputy District Attorney 

931 Parkway Mall 

24 Napa, CA 94559-2647 

25 Telephone: (707) 253-4211 

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1 DONALD A. DU BAIN 

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District Attorney of Solano County 

CRISELDA B. GONZALEZ, SBN 146493 

3 Senior Deputy District Attorney 

Consumer and Environmental Crimes Unit 

4 675 Texas Street, Suite 4500 (41

h Floor) 

Fairfield, CA 94533-6340 

5 Telephone: (707) 784-6800 

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7 JILL R. RA VITCH 

District Attorney of Sonoma County 

8 MATTHEWT. CHEEVER, SBN 191783 

Deputy District Attorney 

9 2300 County Center Drive, Suite B-170 

10 Santa Rosa, CA 95403 

Telephone: (707) 565-2311 

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12 BIRGIT A. FLADAGER 

District Attorney of Stanislaus County 

13 832 12th Street, Suite 300 

14 Modesto, CA 95354 

Telephone: (209) 525-5550 

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16 CARL V. ADAMS 

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District Attorney of Sutter County 

446 Second Street 

18 Yuba City, CA 95992 

Telephone: (530) 822-7330 

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20 GREGG COHEN 

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District Attorney of Tehama County 

444 Oak Street, Room L 

22 Red Bluff, CA 96080 

Telephone: (530) 527-3053 

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24 MICHAEL HARPER 

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District Attorney of Trinity County 

11 Court Street 

26 Weaverville, CA 96093 

Telephone: (530) 623-1304 

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PHILLIP CLINE 

District Attorney of Tulare County 

RODNEY M. BLACO, SBN 212139 

Deputy District Attorney 

221 S. Mooney Blvd., Room 224 

Visalia, CA 93291 

Telephone: (559) 733-6411 

MICHAEL L. KNOWLES 

District Attorney of Tuolumne County 

423 N. Washington Street 

Sonora, CA 95370 

Telephone: (209) 588-5450 

JEFF W. REISIG 

District Attorney ofYolo County 

LARRY BARLLY, SBN 114456 

Supervising Deputy District Attorney 

Consumer Fraud and Environmental Protection Division 

301 Second Street 

Woodland, CA 95695-3415 

Telephone: (530) 666-8180 

PATRICK McGRA TI-l 

District Attorney of Yuba County 

215 Fifth Street, Suite 152 

Marysville, CA 95901 

Telephone: (530) 749-7770 

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2 WHEREAS, this Stipulation for Entry of Final Judgment and Permanent Injunction ("Final 

3 Judgment") is entered into by Plaintiff, the People ofthe State of California ("People") and 

4 . Defendant CVS Pharmacy, Inc. ("Defendant") by their respective attorneys. The People and 

5 Defendant shall be referred to collectively as "Parties." The Parties have stipulated and consented 

6 to the entry of this Final Judgment prior to trial. The Parties have agreed to settle the above 

7 captioned matter without further litigation, as set forth below. 

8 AND WHEREAS, the Court finds that the settlement between the Parties is fair and in the 

9 public interest; 

10 NOW THEREFORE, upon the consent ofthe Parties, it is hereby ORDERED, 

11 ADJUDGED, AND DECREED: 

12 FINAL JUDGMENT AND PERMANENT INJUNCTION ON CONSENT 

13 1. JURISDICTION 

14 The Parties stipulate and agree that the Superior Court of California, County ofVentura, 

15 has subject matter jurisdiction over the matters alleged in this action and personal jurisdiction 

16 over the Parties to this Final Judgment. 

17 2. SETTLEMENT OF DISPUTED CLAIMS. 

18 This Final Judgment is not an admission or a denial by Defendant regarding any issue of 

19 law or fact in the above-captioned matter or any violation of any law. The Parties enter into this 

20 Final Judgment pursuant to a compromise and settlement of disputed claims, as set forth in the 

21 Complaint filed in this action (the "Complaint"), for the purpose of furthering the public interest. 

22 The People believe that the resolution embodied in this Final Judgment is fair and reasonable and 

23 fulfills the People's enforcement objectives; and that except as provided in this Final Judgment, 

24 no further action is warranted concerning the allegations contained in the Complaint. Defendant 

25 agrees that this Final Judgment is a fair and reasonable resolution of the matters alleged in the 

26 Complaint. 

27 All Parties have stipulated and consented to the entry of this Final Judgment prior to the 

28 taking of any proof, and without trial or adjudication of any fact or law herein. The Parties also 

waive their right to appeal. 1 

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1 

2 3. DEFINITIONS 

3 Except where otherwise expressly defined in this Final Judgment, all terms shall be 

4 interpreted consistent with Chapters 6.5 and 6.95 of Division 20 of the Health and Safety Code; 

5 Health and Safety Code sections 117600, et seq.; and the regulations promulgated under these 

6 chapters and sections. 

7 "California Facilities" means the CVS/pharmacy® retail pharmacy stores and CVS® retail 

8 stores, specialty pharmacies and specialty retail pharmacies, distribution centers, medical walk-in 

9 clinics, and tractor trailers used to transport products and materials to and from such facilities, 

10 located in the State of California that, as of April9, 2012, are owned, operated, licensed, or leased 

11 by Defendant (in its own capacity and/or through affiliates identified in Exhibit A-1), including 

12 certain retail pharmacy stores, retail stores, specialty pharmacies and specialty retail pharmacies, 

13 distribution centers, and medical walk-in clinics, that had previously been owned and operated by 

14 third parties not named in this action (and who are collectively identified in Exhibit A-2), that 

15 were thereafter converted to CVS/pharmacy® retail pharmacy stores and CVS® retail stores, 

16 specialty pharmacies and specialty retail pharmacies, distribution centers, medical walk-in clinics 

17 owned, operated, licensed and/or leased by Defendant, either directly or indirectly. A list of the 

18 locations of the California Facilities is provided in Exhibit B-1, attached. The specific list of the 

19 locations of the California Facilities attached as Exhibit B-1 shall not be to the exclusion of other 

20 locations that may have been inadvertently omitted from the list, where the Parties agree in 

21 writing that an omitted location should be included. As to any locations that have been omitted, 

22 Defendant shall provide the following to the People within thirty (30) days after the omission. 

23 comes to the attention ofDefendant: (a) written notice of such additional locations; and (b) to the 

24 best ofDefendant's knowledge and belief, copies of any notices of violation and/or governmental 

25 ·inspection reports applicable to such locations that have been received by that location since April 

26 30, 2005. If, after the People have had sufficient time in which to review the alleged reason for 

27 the omission, and after Defendant has established to the satisfaction of the People that the 

28 omission was inadvertent, the Parties shall agree in writing that the additional location be 

included in the Final Judgment. 2 

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2 "Certified Unified Program Agency" or "CUPA" is an agency certified by the California 

3 Environmental Protection Agency pursuant to the requirements of Chapter 6.11 of the Health and 

4 Safety Code and California Code of Regulations, Title 27, to implement certain State 

5 environmental programs within the local agency's jurisdiction. 

6 "Participating Agency" means an agency that has been designated by the CUP A to 

7 administer one or more state environmental programs on behalf of the CUP A. 

8 "CVS Facilities" means the California Facilities, and each of them, and any additional 

9 CVS/pharmacy® retail pharmacy stores and CVS® retail stores, specialty pharmacies and 

10 specialty retail pharmacies, distribution centers, medical walk -in clinics, and tractor trailers used 

11 to transport products and materials to and from such facilities, in the State of California, that 

12 Defendant may in the future directly or indirectly open, operate, license, or lease in California 

13 that are not listed on Exhibit B-1. 

14 "Former CVS Facilities" means those CVS/pharmacy® retail pharmacy stores and CVS® 

15 retail stores, specialty pharmacies and specialty pharmacy stores, distribution centers, and 

16 medical walk-in clinics that were previously located within the State of California at any time 

17 relevant, but which, as of April 6, 2012 are no longer owned, operated, licensed, or leased by 

18 Defendant (in its own capacity and/or through affiliates identified in Exhibit A-1), including 

19 certain retail pharmacy stores, retail stores, specialty pharmacies and specialty retail pharmacies, 

20 distribution centers, and medical walk-in clinics, that had pr~viously been owned and operated by 

21 third parties not named in this action (and who are collectively identified in Exhibit A-2), that 

22 were thereafter converted to CVS/pharmacy® retail pharmacy stores and CVS® retail stores, 

23 specialty pharmacies and specialty retail pharmacies, distribution centers, medical walk-in clinics 

24 owned, operated, licensed and/or leased by Defendant, either directly or indirectly. A list of the 

25 locations of the Former CVS Facilities is provided in Exhibit B-2, attached. The specific list of 

26 the locations of the Former CVS Facilities attached as Exhibit B-2 shall not be to the exclusion of 

27 other locations that may have been inadvertently omitted from the list, where the Parties agree in 

28 writing that an omitted location should be included. 

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2 4. INJUNCTIVE RELIEF 

3 Pursuant to the provisions ofHealth and Safety Code sections 25181,25516,25516.2, and 

4 Business and Professions Code section 17203, and subject to Paragraph 24 below, Defendant is 

5 permanently enjoined to comply with Chapters 6.5 and 6.95 ofDivision 20 of the Health and 

6 Safety Code; Health & Safety Code sections 117600, et seq.; and the regulations promulgated 

7 under these chapters, at CVS Facilities. Failure to comply with this injunction or any of the 

8 specific additional injunctive provisions that follow, may subject Defendant to sanctions, 

9 including, but not limited to, contempt and/or additional penalties. Paragraph 15, below, applies 

10 to any application or motion for failure to comply with the injunctive provisions of this Final. 

11 Judgment. 

12 4.1 Specific Injunctive Provisions: 

13 Defendant shall comply with each of the following provisions at and from the CVS 

14 Facilities: 

15 4.l.a. Defendant shall not dispose, or cause the disposal of, any hazardous waste at a point 

16 not authorized or permitted by the Department ofToxic Substances Control ("DTSC"), in 

17 violation of Health & Safety Code section 25189, including, without limitation, to any trash 

18 compactor, dumpster, drain, sink, or toilet at any ofthe CVS Facilities, or onto the surface or 

19 subsurface of the ground at any unauthorized location, or at a landfill or transfer station not 

20 authorized to receive hazardous waste. 

21 4.l.b. Defendant shall determine, at each CVS Facility, whether each item returned by a 

22 customer to that facility is a waste and if so, is a "hazardous waste" as required by California 

23 Code of Regulations, title 22, section 66262.11. 

24 4.1.c. Defendant shall determine, at each CVS Facility, whether each waste generated at 

25 that facility as a result of a spill, container breakage or other means rendering the product not 

26 usable for its intended purpose, is a "hazardous waste" as required by California Code of 

27 Regulations, title 22, section 66262.11. 

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2 4.1.d. Defendant shall manage every hazardous waste so identified pursuant to paragraphs 

3 4.l.a., 4.l.b. and 4.l.c in accordance with the requirements of Chapter 6.5 of the Health and 

4 Safety Code and its implementing regulations in the California Code of Regulations, title 22. 

5 4.1.e. Defendant shall not transport, transfer custody of, or cause to be transported, any 

6 hazardous waste unless the transporter is properly licensed and registered to do so, as required by 

7 Health & Safety Code section 25163. This prohibition includes, without limitation, the 

8 transportation of any hazardous waste by a person that is not properly licensed and registered to 

9 transport hazardous waste on a tractor and/or trailer owned or operated by Defendant. 

10 4.1.f. Defendant shall not transport, or cause to be transported, any hazardous waste to an 

11 unauthorized location, in violation ofHealth & Safety Code section 25189.5. 

12 4.l.g. Defendant shall not transport, or cause to be transported, any item that would be 

13 considered hazardous in California pursuant to chapter 11 of Title 22, Division 4.5 of the 

14 California Code of Regulations, as part of its "reverse logistics" process to centralize the 

15 management of returned items at distribution centers owned by Defendant, unless pursuant to a 

16 contractual agreement expressly providing for the return of the item to the manufacturer or the 

17 manufacturer's designated agent, and unless the item is in sufficiently good condition that it may 

18 be donated, resold, reused, or recycled in a manner that does not constitute discard, pursuant to 

19 California Code ofRegulations, Title 22, section 66261.2. 

20 4.1.h. Defendant shall lawfully and timely dispose of all accumulated hazardous waste 

21 from each CVS Facility at least one time during every ninety (90) day period; and shall timely 

22 cause to be prepared and filed with the DTSC a hazardous waste manifest for all hazardous waste 

23 that is transported, or submitted for transportation, for offsite handling, treatment, storage, 

24 disposal, or any combination thereof, as provided by Health & Safety Code section 25160(b)(3) 

25 and California Code of Regulations, Title 22, section 66262.23; and shall timely notify the DTSC 

26 by filing an exception report concerning the treatment, storage, or disposal facility's failure to 

27 return any executed manifest. 

28 4.1.i. Defendant shall contact the transporter and/or the owner or operator of the 

designated facility which was to receive any hazardous waste to determine the status of the 

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2 hazardous waste in the event of non-receipt of a copy of the manifest with the handwritten 

3 signature ofthe owner or operator of the designated facility within thirty-five (35) days ofthe 

4 date the waste was accepted by the initial transporter, as provided by Title 22 of the California 

5 Code ofRegulations section 66262.42. 

6 4 .1.j. Defendant shall not treat, store, dispose of, transport, or offer for transportation, 

7 ariy hazardous waste without having received and used a proper identification number from the 

8 U.S. Environmental Protection Agency or DTSC, for the originating facility, as provided by Title 

9 22 of the California Code of Regulations section 66262.12, subdivision (a). 

10 4 .1.k. Defendant shall maintain a program for the lawful storage, handling and 

11 accumulation of hazardous waste, and for the lawful segregation of hazardous-waste items that 

12 are in leaking containers, as provided by Health & Safety Code section 25123.3 and California 

13 Code ofRegulations, Title 22, sections 66262.34, 66265.173 and 66265.177. 

14 4.1.1. Defendant shall maintain properly designated and designed hazardous waste storage 

15 areas, which include the segregation of hazardous wastes, and shall conduct weekly inspections of 

16 hazardous waste storage areas, at each CVS Facility, as required by California Code of 

17 Regulations, Title 22, sections 66262.34 and 66265.174. 

18 4.1.m. Defendant shall comply with all employee training obligations required by 

19 California Code ofRegulations, Title 22, section 66265.16, pertaining to the handling of 

20 hazardous waste, including, but not limited to, the requirement to maintain for a period ofthree 

21 (3) years, all training documentation for each employee involved in hazardous waste handling at 

22 any CVS Facility. In addition, Defendant shall establish and maintain an employee training plan 

23 designed to enhance employee awareness of any regulatory or statutory changes in environmental 

24 compliance requirements, including, but not limited to, changes in Chapters 6.5 and 6.95 of 

25 Division 20 of the Health & Safety Code, and of any corresponding changes in Defendant's 

26 environmental compliance program(s). 

27 4.1.n. Defendant shall have in place at all times a hazardous waste contingency plan and 

28 emergency procedures for each CVS Facility, as required by California Code of Regulations, 

Title 22, sections 66265.51 through 66265.56. 

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2 4.1.o. Defendant shall, at each CVS Facility, continuously implement, maintain, and 

3 submit to the respective administering agency (as defined in Health and Safety Code sections 

4 25501 and 25502), a complete hazardous materials business plan, as required by Health and 

5 Safety Code sections 25504 and 25505 and California Code ofRegulations, Title 19, section 

6 2729, as applicable. Each hazardous materials business plan shall include procedures for 

7 emergency response to a release or threatened release of hazardous materials, as required by 

8 Health and Safety Code section 25503.5. Such plan shall also include an employee training 

9 program that meets the requirements ofHealth and Safety Code section 25504, subdivisions (a) 

10 and (c), and California Code ofRegulations, Title 19, section 2732. 

11 4.1.p. Defendant shall immediately report any release or threatened release of a reportable 

12 quantity of any hazardous material from any CVS Facility into the environment, as required by 

13 Health and Safety Code sections 25507 and 25501. 

14 4.1.q. Defendant shall properly manage, mark, and store universal waste, as provided by 

15 Title 22 ofthe California Code ofRegulations sections 66273.13- 66273.16 (repealer filed 2-4-

16 2009) and sections 66273.33-66273.36. 

17 4.1.r. Defendant shall keep a record with the information required by section 66273.39, 

18 subdivisions (a)(1)- (3), of each shipment of universal waste received at any CVS Facility, as 

19 provided by Title 22 of the California Code of Regulations section 66273.39. 

20 4.1.s. Defendant shall comply with the California Medical Waste Management Act, Health 

21 and Safety Code sections 117600, et seq. 

22 4.1.t. Defendant shall not knowingly cause to be deposited, without the permission of the 

23 owner, any hazardous substance upon the land of another, in violation of Penal Code section 

24 374.8, subdivision (b). 

25 4.2 Reverse Distribution of Pharmaceuticals: 

26 4.2.a. By June 1, 2012, Defendant shall initiate work with appropriate stakeholders from 

27 business and government, including the U.S. Environmental Protection Agency, the U.S. Food 

28 and Drug Administration, and the California DTSC, to encourage, support, and advocate for 

federal regulatory reform regarding the proper management ofnondispensable pharmaceuticals, 7 

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2 including over-the-counter medications, through "reverse distribution." Such work shall include 

3 coordination and communication with national retail trade associations. Progress on such work 

4 shall be included in the status reports required by Paragraph 23 below. 

5 4.2.b. During the term of this Final Judgment, the People shall only pursue a violation of 

6 this Final Judgment or applicable law regarding the reverse distribution of such nondispensable 

7 pharmaceuticals if Defendant has failed to demonstrate reasonable diligence in performing work 

8 on the federal regulatory reform described in subparagraph 4.2.a above, and provided further, 

9 nothing herein shall prevent the People from pursuing appropriate enforcement of this Final 

10 Judgment or applicable law regarding the reverse distribution ofnondispensable pharmaceuticals 

11 after providing Defendant with ninety (90) days advance written notice as provided by Paragraph 

12 8 of their intent to do so, so as to allow the Parties an opportunity to attempt to resolve any such 

13 dispute by means of good faith informal negotiations. 

14 5. CIVIL PENALTIES, SUPPLEMENTAL ENVIRONMENTAL PROJECTS, 

15 COSTS, AND HAZARDOUS WASTE MINIMIZATION 

16 Defendant shall, within twenty-one (21) business days after entry ofthis Final Judgment, 

17 pay civil penalties, fund the supplemental environmental projects provided for in this Final 

18 Judgment, and pay costs, in the total amount ofTHIRTEEN MILLION, SEVEN HUNDRED 

19 AND FIFTY THOUSAND DOLLARS ($13,750,000.00). Said payment may be made by wire 

20 transfer and shall be made as set forth in paragraphs 5.1, 5.2, 5.4, and 5.5 below. On entry ofthis 

21 Final Judgment, Defendant shall deliver all required payments to the District Attorney's Office 

22 for the County of Ventura, attention: Mitchell F. Disney, Senior Deputy District Attorney, for 

23 distribution pursuant to the terms of this Final Judgment. 

24 5.1 Civil Penalties 

25 Defendant shall pay ELEVEN MILLION DOLLARS ($11,000,000.00) as civil penalties 

26 pursuant to Health and Safety Code sections 25189 and 25 514, and Business and Professions 

27 Code section 17206, to the prosecuting agencies/regulatory agencies identified in, and in 

28 accordance with the terms of, Exhibits C-1 and C-2, attached. 

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2 5.2 Supplemental Environmental Projects 

3 Defendant shall pay TWO MILLION DOLLARS ($2,000,000.00) for supplemental 

4 environmental projects identified in, and in accordance with the terms of, Exhibit D, attached. 

5 5.3 Hazardous Waste Minimization 

6 As remedial measures to minimize hazardous waste generation in California, and not in 

7 mitigation of any penalties sought by the People, Defendant stipulates and agrees that within six 

8 (6) months after entry of the Final Judgment, all California photo processing operations will use 

9 digital/dry photo processing. Further, within six (6) months after entry of the Final Judgment, 

1 o Defendant will dedicate, at a minimum, two (2) full-time employees trained in and designated as 

11 responsible for environmental, health, and safety compliance assurance within the State of 

12 California. Defendant shall also continue the use of new software developed for its radio 

13 frequency units to enhance Defendant's management of damaged items at store level. 

14 5.4 Reimbursement of Costs of Investigation and Enforcement 

15 Defendant shall pay SEVEN HUNDRED AND FIFTY THOUSAND DOLLARS 

16 ($750,000.00), for reimbursement of attorney's fees, costs of investigation, and other costs of 

17 enforcement, to the entities identified in, and in accordance with the terms of, Exhibits E-1 and 

18 E-2, attached. 

19 5.5 Copy of Payments to Plaintiff's Representatives 

20 Defendant shall, at the time of payment, send an electronic confirmation of any payment 

21 made by wire transfer to the People's representative identified in paragraph 8. 

22 6. ENFORCEMENT OF FINAL JUDGMENT AND PENALTIES 

23 The People may move this Court for additional relief for any violation of any provision of 

24 this Final Judgment, including but not limited to contempt, additional injunctive provisions, or 

25 additional penalties consistent with the provisions of this Final Judgment. Nothing in this Final 

26 Judgment shall limit any rights of the People to seek any other relief or remedies provided by law, 

27 or the rights of Defendant to defend against any request of the People for such other relief or 

28 remedies. 

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2 7. MATTERS COVERED BY THIS FINAL JUDGMENT 

3 7.1 This Final Judgment is a final and binding resolution and settlement of all claims, 

4 violations or causes of action expressly alleged by the People in the Complaint or claims that 

5 could have been asserted within the scope of the allegations set forth in the Complaint ("Covered 

6 Matters"), against Defendant and its subsidiaries, affiliates and corporate parents, and each of 

7 their affiliates and parents, California Facilities and Former CVS Facilities, successors, heirs, 

8 assigns, managed medical groups, and their respective officers, directors, partners, employees, 

9 agents, representatives, property owners, and facility operators ("Entities Covered by Final 

10 Judgment"). The People further covenant not to sue the Entities Covered by Final Judgment for 

11 any Covered Matter. Any claim, violation, or cause of action that is not a Covered Matter is a 

12 "Reserved Claim." Reserved Claims include, without limitation, any violation that occurs after 

13 the Court's entry of this Final Judgment. Nothing herein shall be interpreted to restrict any claims 

14 that the People may assert against any independent contractors or subcontractors of the California 

15 Facilities or the Former CVS Facilities for violations of applicable laws by such parties. The 

16 People reserve the right to pursue any Reserved Claim, and Defendant reserves its defenses 

17 against any Reserved Claim. 

18 7.2 Any claims or causes of action against Defendant for performance of cleanup, 

19 corrective action, or response action for any actual past or future release, spill, or disposal of any 

20 hazardous waste, hazardous substance, hazardous material, universal waste, sharps waste, 

21 pharmaceutical waste, photo waste with silver, or any other material, substance or waste, that is 

22 caused or contributed to by the Defendant at or from its California Facilities, and any claims or 

23 causes of action for performance of cleanup, corrective action, or response action relating to 

24 Defendant's disposal of same that are discovered by the People after execution of this Agreement 

25 are Reserved Claims. 

26 7.3 In any subsequent action that may be brought by the People based on any Reserved 

27 Claim, Defendant agrees that it will not assert that failing to pursue the Reserved Claims as part 

28 of this action constitutes claim-splitting. This Paragraph does not affect any statute of limitations, 

if any, which may be applicable to any Reserved Claim or claims otherwise excluded from this 

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1 

2 Final Judgment and does not prohibit Defendant from asserting any statute of limitations or other 

3 legal or equitable defenses that may be applicable to any Reserved Claims. 

4 7.4 In the event litigation is filed by an entity that is not a party to this action against 

5 Defendant or any affiliates arising out of or related to a Covered Matter, Defendant may, within 

6 thirty (30) days following service of such litigation, notify the People of such litigation. Upon 

7 such timely notice, the People will undertake a good faith effort to determine whether the 

8 subsequent litigation is barred by the terms ofthis Final Judgment and the principle of res 

9 judicata. If the People determine that the subsequent litigation is barred by the terms of this Final 

10 Judgment and the principle of res judicata, the People may appear in person or in writing in such 

11 subsequent litigation to explain the People's view of the effect ofthis Final Judgment on such 

12 litigation and the People will not oppose Defendant in arguing that the subsequent litigation is 

13 barred by the principle of res judicata. No language in this paragraph will preclude Defendant 

14 from asserting in any subsequent litigation any and all applicable legal and equitable defenses 

15 regarding compliance with any provision in this Final Judgment or the laws or regulations cited in 

16 this Final Judgment or cited in the Complaint, including, but not limited to, res judicata. 

17 7.5 The provisions of paragraph 7.1 are effective on the date of entry of the Final 

18 Judgment. The continuing effect of paragraph 7.1 is expressly conditioned on Defendant's full 

19 payment of the amounts due under this Final Judgment and compliance with its injunctive terms. 

20 7.6 Paragraph 7.1 does not limit the ability of the People to enforce the terms of this Final 

21 Judgment. 

22 7.7 Defendant covenants not to pursue any civil or administrative claims against the People 

23 or against any agency ofthe State of California, any county in the State of California or any 

24 CUPA, Participating Agency or local agency (collectively "Agencies"), or against any of their 

25 officers, employees, representatives, agents or attorneys, arising out of or related to any Covered 

26 Matter; provided, however, that if any Agencies initiate claims against Defendant, Defendant 

27 reserves any and all rights, claims, demands and defenses against such Agencies. 

28 7.8 Any event that is beyond the control of Defendant and that prevents it from timely 

performing any obligation under paragraph 4 of

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tfis Final Judgment, despite its best efforts to 

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fulfill that obligation, is a "force majeure" event. The requirement that Defendant exercise its 

"best efforts to fulfill the obligation" includes the requirement that Defendant use its best efforts 

to anticipate any potential force majeure event and use best efforts to address the effects of any 

potential force majeure event: (1) as it is occurring, and (2) following the force majeure event, 

such that the delay is minimized to the greatest extent possible. "Force majeure" does not include 

financial inability to fund or complete the obligation. 

I 022112 

8. NOTICE 

All submissions and notices required by this Final Judgment shall be sent to: 

For the People: 

Mitchell F. Disney 

Senior Deputy District Attorney 

Office of the District Attorney 

Special Prosecutions Division 

5720 Ralston Street, No. 300 

Ventura, CA 93003 

With a copy to: 

David J. Irey 

Supervising Deputy District Attorney 

Office of the District Attorney San Joaquin County 

222 E. Weber Ave., Room 202 

Stockton, CA 95202 

For Defendant: 

Vice President and Corporate Secretary 

CVS Pharmacy, Inc. 

One CVS Drive 

Woonsocket, RI 02895 

With copy to: 

Director of Environmental Management 

CVS Pharmacy, Inc. 

One CVS Drive 

Woonsocket, RI 02895 

12 

STIPULATION FOR ENTRY 01<' FINAL JUDGMENT AND PERMANENT INJUNCTION 
2 Any Party may change its notice name and address by informing the other party in writing, 

3 but no change is effective until it is received. All notices and other communications required or 

4 permitted under this Final Judgment that are properly addressed as provided in this paragraph are 

5 effective upon delivery if delivered personally or by overnight mail, or are effective five (5) days 

6 following deposit in the United States mail, postage prepaid, if delivered by mail, or the day that 

7 electronic mail is sent if sent before 5 p.m. tQ the electronic mail addresses of the designated 

8 recipients for notice concurrent with sending the notice by overnight mail. 

9 9. EFFECT OF FINAL JUDGMENT 

10 Except as expressly provided in this Final Judgment, nothing in this Final Judgment is 

11 intended nor shall it be construed to preclude the People, or any state, county, or local agency, 

12 depart~ent, board or entity, or any CUPA, from exercising its authority under any law, statute or 

13 regulation. Except as expressly provided in this Final Judgment, Defendant retains all of its 

14 defenses to the exercise of the aforementioned authority. 

15 10. LIABILITY OF THE PEOPLE 

16 The People shall not be liable for any injury or damage to any person or property resulting 

17 from any act or omission by Defendant, or any of its directors, officers, employees, agents, 

18 representatives or contractors, in carrying out activities pursuant to this Final Judgment, nor shall 

19 the People be held as a party to or guarantor of any contract entered into by Defendant, its 

20 directors, officers, employees, agents, representatives or contractors, in carrying out the 

21 requirements ofthis Final Judgment. 

22 11. NO WAIVER OF RIGHT TO ENFORCE 

23 The failure of the People to enforce any provision of this Final Judgment shall neither be 

24 deemed a waiver of such provision nor in any way affect the validity of this Final Judgment. The 

25 failure of the People to enforce any such provision shall not preclude them from later enforcing 

26 the same or any other provision of this Final Judgment, subject to Paragraph 24. Except as 

27 expressly provided in this Final Judgment, Defendant retains all defenses allowed by law to any 

28 such later enforcement. No oral advice, guidance, suggestions or comments by employees or 

13 

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I 022112 
1 

2 officials of any Party regarding matters covered in this Final Judgment shall be construed to 

3 relieve any Party of its obligations undet: this Final Judgment. 

4 12. FUTURE REGULATORY CHANGES 

5 Nothing in this Final Judgment shall excuse Defendant from meeting any more stringent 

6 requirement that may be imposed by applicable law or by any change in the applicable law. To 

7 the extent any future statutory or regulatory change makes Defendant's obligations less stringent 

8 than those provided for in this Final Judgment, it may apply to this Court on noticed motion for 

9 modification ofthose obligations contained herein. 

10 13. APPLICATION OF FINAL JUDGMENT 

11 This Final Judgment shall apply to and be binding upon the People and upon Defendant and 

12 its officers, managers, employees, agents, successors and assigns. 

13 14. AUTHORITY TO ENTER FINAL JUDGMENT 

14 Each signatory to this Final Judgment certifies that he or she is fully authorized by the party 

15 he or she represents to enter into this Final Judgment, to execute it on behalfofthe party 

16 represented, and to legally bind that party. 

17 15. CONTINUING JURISDICTION 

18 The Court shall retain continuing jurisdiction to enforce the terms ofthis Final Judgment 

19 and to address any other matters arising out of or regarding this Final Judgment. The Parties shall 

20 meet and confer at least ten (1 0) days prior to the filing of any application or motion relating to 

21 this Final Judgment, and shall negotiate in good faith in an effort to resolve any dispute without 

22 judicial intervention; provided, however, that the ten (10) day period referenced above shall be 

23 shortened to five (5) days regarding any alleged violation of paragraph 4.l.a of this Final 

24 Judgment. If the Parties are unable to resolve their dispute after meet-and-confer discussions, any 

25 Party may move this Court seeking a resolution of that dispute by the Court. 

26 16. ABILITY TO INSPECT AND COPY RECORDS AND DOCUMENTS 

27 On reasonable notice, Defendant shall permit any duly authorized representative of the 

28 People to inspect and copy records and documents as they deem reasonably necessary to 

determine compliance with the terms of this Final Judgment. Nothing in this paragraph is 

14 

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I 022112 
2 intended to require access to or production of any documents that are protected from production 

3 or disclosure by the attorney-client privilege, attorney work product doctrine, any other applicable 

4 privilege, defense, exemption, or immunity afforded to Defendant under applicable law, nor does 

5 it waive any of the objections or defenses to which Defendant would be entitled in responding to 

6 requests for documents made by subpoena or other formal legal process or discovery. This 

7 obligation shall not require Defendant to alter its normal document-retention policies (including 

8 but not limited to policies regarding backup tapes for electronic documents); provided, however, 

9 that Defendant's policies must comply with Health and Safety Code Chapters 6.5 and 6.95; 

10 Health and Safety Code sections 117600, et seq.; and their implementing regulations. The Parties 

11 agree that Defendant may not be deemed in violation of this Paragraph for failure to maintain 

12 such records unless Defendant fails to exercise reasonable diligence in administering this record 

13 retention requirement. Nothing in this paragraph is intended to limit the authority of any 

14 governmental agency to inspect Defendant or its records and documents under applicable law. 

15 17. PAYMENT OF LITIGATION EXPENSES AND FEES 

16 Defendant shall make no request ofthe People to pay its attorneys fees, expert witness fees 

17 and costs and all other costs of litigation and investigation incurred to date. 

18 18. INTERPRETATION 

19 This Final Judgment was drafted equally by all Parties. The Parties agree that the rule of 

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

21 interpretation ofthis Final Judgment. 

22 19. COUNTERPART SIGNATURES 

23 This Final Judgment may be executed by the Parties in counterpart. 

24 20. ENTRY AFTER NOTICED MOTION 

25 The Parties seek approval of this Final Judgment on noticed motion and have requested that 

26 the Court make a determination that the Final Judgment is fair and in the public interest. 

27 

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I 022112 

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21. INTEGRATION 

This Final Judgment constitutes the entire agreement between the Parties and may not be 

amended or supplemented except as provided for herein. No oral representations have been made 

or relied upon other than as expressly set forth herein. 

22. MODIFICATION OF FINAL JUDGMENT 

This Final Judgment may be modified only on noticed motion by one of the Parties with 

approval ofthe court, or upon written consent by all ofthe Parties and the approval of the court. 

23. STATUS REPORTS 

Beginning six (6) months after entry of this Final Judgment, for as long as this Final 

( 

Judgment remains in effect, Defendant shall submit an annual status report to the People's 

representative listed in Section 8 above. The status report shall: briefly summarize the actions 

that Defendant has taken at the corporate level related to California and the CVS Facilities during 

the previous year in order to comply with its obligations under this Final Judgment; disclose and 

provide copies of any notices of violation that Defendant has received pertaining to 

environmental matters in the State of California, and disclose any corrective measures taken as a 

result; and set forth any penalties Defendant has paid to any governmental agency for alleged 

noncompliance with any environmental statute or regulation arising from business operations in 

California. Each status report shall be signed by an Officer ofDefendant under penalty of perjury 

that to the best of his or her knowledge based on information and belief and after reasonable 

investigation the information contained therein is true and correct. Provided, further, that 

beginning one year after entry of this Final Judgment, and continuing for as long as this Final 

Judgment remains in effect, Defendant shall, at the People's request, on an annual basis, meet to 

describe to the People's representatives the status ofDefendant's reverse logistics program and 

compliance with Paragraph 4, 4.1, and 4.2 ofthis Judgment. 

24. TERMINATION OF FINAL JUDGMENT 

At any time after this Final Judgment has been in effect for five (5) years, and Defendant 

has paid any and all amounts due under the Final Judgment, any party may provide notice to the 

Court (which shall be served on all parties) that the injunctive provisions of this Final Judgment 

16 

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I 022112 
2 should expire and have no further force and effect ("Notice of Termination"). The injunctive 

3 provisions of this Final Judgment will be of no further force or effect sixty (60) days thereafter, 

4 unless the People file a motion contesting the expiration of any injunctive provisions within forty 

5 (40) days of receipt ofthe Notice ofTermination. In the event that such motion is filed, none of 

6 the injunctive provisions of the Final Judgment contested in the People's motion will terminate 

7 pending the Court's ruling on the motion. The People reserve the right to contest termination 

8 exclusively on the grounds that Defendant has not substantially complied in all material respects 

9 with the injunctive provisions of the Final Judgment or has not been reasonably diligent in 

10 pursuing the actions described in Paragraph 4.2(a), and to offer any evidence relevant to such 

11 motion. Defendant reserves its rights to respond to any ground raised in the People's motion and 

12 to offer any evidence relevant to such motion. The injunctive provisions in the Final Judgment 

13 will expire and be of no further force or effect unless the Court (upon consideration of the Parties' 

14 pleadings and arguments, if any) determines that the expiration ofthe provision at issue would 

15 not be in the interest of justice, because Defendant has not substantially complied in material 

16 respects with such provision or has not been reasonably diligent in pursuing the actions described 

17 in Paragraph 4.2(a). The termination ofthe injunctive provisions ofthe Final Judgment shall 

18 have no effect on Defendant's obligation to comply with the requirements imposed by statute, 

19 regulation, ordinance, or law. · 

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IT IS SO STIPULATED. 

FOR THE PEOPLE: 

DATED: 

GREGORY D. TOTTEN, District Attorney 

County ofVentura, State of California 

By:~ ITCHELL F. DIS Y 

Senior Deputy District Attorney 

Attorneys for Plaintiff 

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DATED: l.f/q I tr 

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DATED: 

DATED: 

CARMEN A. TRUT ANICH, City Attorney 

City of Los Angeles, State of California 

,_/----; /? J 

/1J;,. /~v------- . . DONALD K~S 

Assistant City Attorney 

Attorneys for Plaintiff 

STEVE COOLEY, District Attorney 

County of Los Angeles, State of California 

By: ~~----------------------------- DANIEL J. WRIGHT 

Deputy District Attorney 

Attorneys for Plaintiff 

BONNIE M. DUMANIS, District Attorney 

County of San Diego, State of California 

By: ~KA~RE--N--I.~D~O~T_Y ________________ _ 

Deputy District Attorney 

Attorneys for Plaintiff 

JAMES P. WILLETT, District Attorney 

County of San Joaquin, State of California 

By: ~------~~--------------------- DAVID J. IREY 

Supervising Deputy District Attorney 

Attorneys for Plaintiff 

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DATED: 

DATED: 

DATED: 

DATED: 

CARMEN A. TRUTANICH, City Attorney 

City of Los Angeles, State of California 

By: --------------------------------

DONALDKASS 

Assistant City Attorney 

Attorneys for Plaintiff 

STEVE COOLEY, District Attorney 

County of Los Angeles, State of California 

By:D~f~ Deputy District Attorney 

Attorneys for Plaintiff 

BONNIE M. DUMANIS, District Attorney 

County of San Diego, State of California 

By: ---------------------------------

KAREN I. DOTY 

Deputy District Attorney 

Attorneys for Plaintiff 

JAMES P. WILLETT, District Attorney 

County of San Joaquin, State of California 

By: ---------------------------------

DAVID J. IREY 

Supervising Deputy District Attorney 

Attorneys for Plaintiff 

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DATED: 

DATED: 

DATED: 

DATED: 

CARMEN A. TRUTANICH, City Attorney 

City of Los Angeles, State of California 

By: --------------------------------

DONALDKASS 

Assistant City Attorney 

Attorneys for Plaintiff 

STEVE COOLEY, District Attorney 

County of Los Angeles, State of California 

By: _D_A_N_I_E_L_J-.W--R-IG~H~T---------------

Deputy District Attorney 

Attorneys for Plaintiff 

BONNIE M. DUMANIS, District Attorney 

County of San Diego, State of California 

By: _&----""~ __ J __ . ~_'f" __ _ KAREN I. DOTY 

Deputy District Attorney 

Attorneys for Plaintiff 

JAMES P. WILLETT, District Attorney 

County of San Joaquin, State of California 

By: -------------------------------- DAVID J. IREY 

Supervising Deputy District Attorney 

Attorneys for Plaintiff 

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DATED: 

DATED: 

DATED: 

DATED: ilt/tlCARMEN A. TRUTANICH, City Attorney 

City ofLos Angeles, State of California 

By: ~~----~~~------~----------

DONALDKASS 

Assistant City Attorney 

Attorneys for Plaintiff 

STEVE COOLEY, District Attorney 

County of Los Angeles, State of California 

By: ~D~A~N~I=E=L=J~.=w=R=Io=H=T=--------------

Deputy District Attorney 

Attorneys for Plaintiff 

BONNIE M. DUMANIS, District Attorney 

County of San Diego, State of California 

By: -KA~R-E=N~L=n=o=T=Y~---------------

Deputy District Attorney 

Attorneys for Plaintiff 

JAMES P. WILLETT, District Attorney 

County of San Jo · of California 

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2 ADDITIONAL COUNSEL FOR PLAINTIFF: 

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DATED: 

DATED: 

DATED: 

DATED: 

NANCY E. O'MAU..,EY, District Attomey 

County of Alameda, State of California 

TODD D. RIEBE, Distdct Attomey 

County of Amador, State of California 

By: David J. lrey for 

--------------------~---------- TODD D. RIEBE 

District Attomey 

Attorneys for Plaintiff 

MICHAEL L. RAMSEY, District Attomey 

County of Butte, State of California 

By: David J. lrey for 

~M~IC~H~A~E~L~L~.~RA~M~s=E~Y~-----------

District Attomey 

Attomeys for Plaintiff 

BARBARA M. YOOK, District Attomey 

County of Calaveras, State of Califomia 

By: David J. lrey for 

-------------------------------- BARBARA M. YOOK 

District Attomey 

Attomeys for Plaintiff 

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DATED: 

DATED: 

DATED: 

DATED: 

NANCY E. O'MALLEY, District Attorney 

County of Alameda, State of California 

By: ~~~~~~~~=---------------

KENNETH A. MIFSUD 

Senior Deputy District Attorney 

Attorneys for Plaintiff 

TODD D. RIEBE, District Attorney 

County of Amador, alifornia 

Di net Attorney 

Attorneys for Plainti 

District Attorne 

Attorneys for Plaint1tl" .,.___.-

David J. Irey for 

David J. Irey for 

BARBARA M. YOOK, District Attorney 

County of , _ te of California 

District Attorn 

Attorneys for Pia · f 

---

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David J. Irey for 

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DATED: 

DATED: 

DATED: 

MARK A. PETERSON, District Attorney 

County of Contra Costa, State of California 

By: ~___. X1v.JYa~ ST · --... SINI 

Deputy District Attorney 

Attorneys for Plaintiff 

VERN PIERSON, District Attorney 

County of El Dorado, State of California 

By: David J. Trey for 

-------------------------------- VERN PIERSON 

District Attorney 

Attorneys for Plaintiff 

ELIZABETH A. EGAN, District Attorney 

County of Fresno, State of California 

By: -------------------------------- MICHAEL BRUMMEL 

Deputy District Attorney 

Attorneys for Plaintiff 

ROBERT MALONEY, District Attorney 

County of Glenn, State of California 

By: David J. Trey for 

-------------------------------- ROBERT MALONEY 

District Attorney 

Attorneys for Plaintiff 

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DATED: 

DATED: 

DATED: 

DATED: 

MARK A. PETERSON, District Attorney 

County of Contra Costa, State of California 

By: ~s=T~A-c=E~Y-G=R~A~s=s~IN=I~------------

Deputy District Attorney 

Attorneys for Plaintiff 

District Attorney 

Attorneys for Plain · f 

David J. Irey for 

ELIZABETH A. EGAN, District Attorney 

County ofFresno, State of California 

By: -------------------------------- MICHAEL BRUMMEL 

Deputy District Attorney 

Attorneys for Plaintiff 

ROBERT MALONEY, District Attorney 

County of te of California 

David J. Irey for 

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DATED: 

DATED: 

DATED:APelt..- "1 12.012-

DATED: 

MARK A. PETERSON, District Attorney 

County of Contra Costa, State of California 

By: -s=T~A~C~E~Y~G~RA--S~s=w~I--------------

Deputy District Attorney 

Attorneys for Plaintiff 

VERN PIERSON, District Attorney 

County of El Dorado, State of California 

By: David J. Irey for 

-------------------------------- VERN PIERSON 

District Attorney 

Attorneys for Plaintiff 

Deputy District Attorney 

Attorneys for Plaintiff 

ROBERT MALONEY, District Attorney 

County of Glenn, State of California 

By: David J. Irey for 

-------------------------------- ROBERT MALONEY 

District Attorney 

Attorneys for Plaintiff 

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DATED: 

DATED: 

DATED: 

DATED: 

PAUL V.G ALLEGOS, District Attorney 

County of Humboldt, State of California 

By: David J. Irey for 

-------------------------------- PAUL V.G ALLEGOS 

District Attorney 

Attorneys for Plaintiff 

LISA S. GREEN, District Atto ey 

County o Kern, State of Cali for ia 

uty District Attorney 

orneys for Plaintiff 

GREG STRICKLAND,D istrict Attorney 

County ofKings, State of California 

By: David J. lrey for 

-------------------------------- GREG STRICKLAND 

District Attorney 

Attorneys for Plaintiff 

DON A. ANDERSON, District Attorney 

County of Lake, State ofCalifornia 

By: David J. Irey for 

-------------------------------- DON A. ANDERSON 

District Attorney 

Attorneys for Plaintiff 

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2 MICHAEL R. KEITZ, District Attorney 

County of Madera, State of California 

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4 DATED: rM~ By: David J. Irey for 

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8 EDWARD S. BERBERIAN, JR., District 

Attorney 

9 County ofMarin, State of California 

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DATED: By: 

11 ANDRES H. PEREZ 

12 Deputy District Attorney 

Attorneys for Plaintiff 

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14 C. DAVID EYSTER, District Attorney 

15 County of State of California 

16 wz_ David J. Trey for DATED: By: 

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District Attar 

18 Attorneys for Pia 

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20 LARRY D. MORSE, District Attorney 

County of Me· ate of California 

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22 DATED: r/tlr2- By: David J. Trey for 

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MICHAEL R. KEITZ, District Attorney 

County of Madera, State of California 

David J. Trey for By: ~M~rc=H-A=E~L=R=.~KE~~I-T_Z ____________ __ 

District Attorney 

Attorneys for Plaintiff 

EDWARD S. BERBERIAN, JR., District 

Attorney 

County of Marin, State of California 

By ANDRES ~tj~ H. PEREZ ~ 

Deputy District Attorney 

Attorneys for Plaintiff 

C. DAVID EYSTER, District Attorney 

County of Mendocino, State of California 

By: _________________________ Da_vt_·d_J._Ire_y_fu __ r 

C. DAVID EYSTER 

District Attorney 

Attorneys for Plaintiff 

LARRY D. MORSE, District Attorney 

County of Merced, State of California 

By: _________________________ Da_v_id_J._ue_y_fu __ r 

LARRY D. MORSE 

District Attorney 

Attorneys for Plaintiff 

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DATED: 

DATED: 

DATED: 

GARY LIEBERSTEIN, District Attorney 

County of Napa, State of California 

By: ------------------------------ CATHERINE C. BORSETTO 

Deputy District Attorney 

Attorneys for Plaintiff 

CLIFFORD NEWELL, District Attorney 

County of Nevada, State of California 

By: David J. Irey for 

------------------------------ CLIFFORD NEWELL 

District Attorney 

Attorneys for Plaintiff 

TONY RACKAUCKAS, District Attorney 

County of Orange, State of California 

By: ~w==~-L~IA~M~G~.=FA~L~L~O=N~-----------

Deputy District Attorney 

Attorneys for Plaintiff 

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DATED: 

DATED: !Jf!-1/ ~ :2-tJ/2._ 

DATED: 

DATED: 

DEAN D. FLIPPO, District Attorney 

County of Monterey, State of California 

By: --------~~------------~------ ANNE M. MICHAELS 

Managing Deputy District Attorney 

Attorneys for Plaintiff 

Deputy District Attorney 

Attorneys for Plaintiff 

CLIFFORD NEWELL, District Attorney 

County of Nevada, State of California 

By: ________________________ n_av_id_J._Ire_y_fu __ r 

CLIFFORD NEWELL 

District Attorney 

Attorneys for Plaintiff 

TONY RACKAUCKAS, District Attorney 

County of Orange, State of California 

By: -------------------------------- WILLIAM G. FALLON 

. Deputy District Attorney 

Attorneys for Plaintiff 

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DATED: 

DATED: 

DATED: #z..-

DATED: 

DEAN D. FLIPPO, District Attorney 

County of Monterey, State of California 

By: -A~NN~E--M~.~M~I~C=H~A=E~L~S-------------

Managing Deputy District Attorney 

Attorneys for Plaintiff 

GARY LIEBERSTEIN, District Attorney 

County of Napa, State of California 

By: ____________________________ __ 

CATHERINE C. BORSETTO 

Deputy District Attorney 

Attorneys for Plaintiff 

CLIFFORD NEWELL, District Attorney 

County ofNev State of California 

David J. Trey for 

TONY RACKAUCKAS, District Attorney 

County of Orange, State of California 

By: -------------------------------- WILLIAM G. FALLON 

Deputy District Attorney 

Attorneys for Plaintiff 

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DATED: 

DATED: 

DATED: 

DATED: '1/t/;:L 

~~ 

DEAN D. FLIPPO, District Attorney 

County of Monterey, State of California 

By: --------------------------------- ANNE M. MICHAELS 

Managing Deputy District Attorney 

Attorneys for Plaintiff 

GARY LIEBERSTEIN, District Attorney 

County ofNapa, State of California 

By: -C~A~T=H=E=R~IN~E-C~.~B~O=R~S=E=TT==o----------

Deputy District Attorney 

Attorneys for Plaintiff 

CLIFFORD NEWELL, District Attorney 

County ofNevada, State of California 

David J. lrey for By: --------------------------------- CLIFFORD NEWELL 

District Attorney 

Attorneys for Plaintiff 

TONY RACKAUCKAS, District Attorney 

County of Orange, State of California 

B~ Deputy District Attorney 

Attorneys for Plaintiff 

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DATED: WaDATED: 

DATED: 

DATED: 

R. SCOTT OWENS, District Attorney 

County ofPlace · te of California 

David J Irey for 

PAUL ZELLERBACH, District Attorney 

County of Riverside, State of California 

By: -------------------------------- DALE C. HOY II 

Deputy District Attorney 

Attorneys for Plaintiff 

JAN SCULLY, District Attorney 

County of Sacramento, State of California 

By: --------------------------------

DOUGLAS WHALEY 

Deputy District Attorney 

Attorneys for Plaintiff 

MICHAEL A. RAMOS, District Attorney 

County of San Bernardino, State of California 

By: --------------------------------

DANIEL SILVERMAN 

Deputy District Attorney 

Attorneys for Plaintiff 

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STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION 

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DATED: 

DATED: 'i "f f-o/;;/.. 

DATED: 

DATED: 

R. SCOTT OWENS, District Attorney 

County of Placer, State of California 

By: David J. lrey for 

--------------------------------

R. SCOTT OWENS 

District Attorney 

Attorneys for Plaintiff 

JAN SCULLY, District Attorney 

County of Sacramento, State of California 

By: --------------------------------

DOUGLAS WHALEY 

Deputy District Attorney 

Attorneys for Plaintiff 

MICHAEL A. RAMOS, District Attorney 

County of San Bernardino, State of California 

By: --------------------------------

DANIEL SIL YERMAN 

Deputy District Attorney 

Attorneys for Plaintiff 

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DATED: 

DATED: 

DATED: I I 

DATED: 

R. SCOTT OWENS, District Attorney 

County of Placer, State of California 

By: David J. lrey for 

----------==--------------------

R. SCOTT OWENS 

District Attorney 

Attorneys for Plaintiff 

PAUL ZELLERBACH, District Attorney 

County of Riverside, State of California 

By: -D~A-L-E~C~.H~O=Y~I=I~---------------

Deputy District Attorney 

Attorneys for Plaintiff 

MICHAEL A. RAMOS, District Attorney 

County of San Bernardino, State of California 

By: -------------------------------- DANIEL SIL YERMAN 

Deputy District Attorney 

Attorneys for Plaintiff 

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STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION 

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DATED: 

DATED: 

DATED: 

DATED: 

R. SCOTT OWENS, District Attorney 

County of Placer, State of California 

David J. lrey for By: -------------------------------- R. SCOTT OWENS 

District Attorney 

Attorneys for Plaintiff 

PAUL ZELLERBACH, District Attorney 

County of Riverside, State of California 

By: --------~~=------------------- DALE C. HOY II 

Deputy District Attorney 

Attorneys for Plaintiff 

JAN SCULLY, District Attorney 

County of Sacramento, State of California 

By: -------------------------------- DOUGLAS WHALEY 

Deputy District Attorney 

Attorneys for Plaintiff 

MICHAEL A. RAMOS, District Attorney 

County of San Bernardino, State of California 

By: ~· ??~- s/2. 

DANIEL SIL YERMAN 

Deputy District Attorney 

Attorneys for Plaintiff 

24 

STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION 

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DATED: Lf-'1·12.. 

DATED: 

DATED: 

DATED: 

JAN GOLDSMITH, City Attomey 

City of San Diego, State of Califomia 

By: -~--=-~~~r....::__:_:~:__:____..=-- MICHAEL R. HUDSON 

Deputy City Attomey 

Attomeys for Plaintiff 

GEORGE GASCON, District Attomey 

County of San Francisco, State of California 

By: -------------------------------- MAXWELLS. PELTZ 

Assistant District Attomey 

Attomeys for Plaintiff 

GERALD T. SHEA, District Attomey 

County of San Luis Obispo, State of Califomia 

By: ____________________________ ___ 

STEVEN D. VON DOHLEN 

Deputy District Attomey 

Attomeys for Plaintiff 

STEPHEN M. W AGSTAFFE, District Attomey 

County of San Mateo, State of Califomia 

By: -------------------------------- JOHN E. WILSON 

Deputy District Attomey In Charge 

Attomeys for Plaintiff 

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DATED: 

DATED: vt/cr I 1~ I I 

DATED: 

DATED: 

JAN GOLDSMITH, City Attorney 

City of San Diego, State of California 

By: -------------------------------- MICHAEL R. HUDSON 

Deputy City Attorney 

Attorneys for Plaintiff 

GEORGE GASC6N, District Attorney 

County of San Francisco, State of California 

By:~ MAXWELLS:Pfrz 

Assistant District Attorney 

Attorneys for Plaintiff 

GERALD T. SHEA, District Attorney 

County of San Luis Obispo; State of California 

By: -------------------------------- STEVEN D. VON DOHLEN 

Deputy District Attorney 

Attorneys for Plaintiff 

STEPHEN M. W AGSTAFFE, District Attorney 

County of San Mateo, State of California 

By: -------------------------------- JOHN E. WILSON 

Deputy District Attorney In Charge 

Attorneys for Plaintiff 

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STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION 

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DATED: 

DATED: 

DATED: 

DATED: 

JAN GOLDSMITH, City Attorney 

City of San Diego, State of Califomia 

By: -------------------------------- MICHAEL R. HUDSON 

Deputy City Attorney 

Attorneys for Plaintiff 

GEORGE GASCON, District Attorney 

County of San Francisco, State of California 

By: ----=--------------------------- MAXWELLS. PELTZ 

Assistant District Attorney 

Attorneys for Plaintiff 

GERALD T. SI-ffiA, District Attomey 

County of San LJ.Ii&9eisp_o, State of California 

;; ·~ 

David J. Irey for 

STEPHEN M. WAGSTAFFE, District Attorney 

County of San Mateo, State of California 

By: ~--~-------------------------- JOHN E. WILSON 

Deputy District Attorney In Charge 

Attorneys for Plaintiff 

25 

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DATED: 

DATED: 

DATED: 

DATED: lf-q-12.. 

JAN GOLDSMITH, City Attorney 

City of San Diego, State of California 

By: --------------~---------------- MICHAEL R. HUDSON 

Deputy City Attorney 

Attorneys for Plaintiff 

GEORGE GASCON, District Attorney 

County of San Francisco, State of California 

By: -------------------------------- MAXWELL S. PELTZ 

Assistant District Attorney 

Attorneys for Plaintiff 

GERALD T. SHEA, District Attorney 

County of San Luis Obispo, State of California 

By: ______________________________ _ 

STEVEN D. VON DOHLEN 

Deputy District Attorney 

Attorneys for Plaintiff 

STEPHEN M. W AGSTAFFE, District Attorney 

County of San Mateo, State of California 

J 

ty District Attorney In Charge 

Attorneys for Plaintiff 

25 

STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION 

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DATED: 

DATED: 

DATED: 

DATED: 

JEFFREY F. ROSEN, District Attorney 

County of Santa C ~ of California 

David J. Irey for 

BOB LEE, District Attorney 

County of Santa Cruz, State of California 

By: ~w==~~L~IA __ M_A_T=K=IN~S~O~N~-----------

Supervising Assistant District Attorney 

Attorneys for Plaintiff 

STEPHEN CARL TON, District Attorney 

County of Sh e of California 

DONALD A. DU BAIN, District Attorney 

County of Solano, State of California 

By: ----------------------~--------

CRISELDA B. GONZALEZ 

Senior Deputy District Attorney 

Attorneys for Plaintiff 

26 

STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION 

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DATED: 

DATED: lj;'\~\~ 

DATED: 

DATED: 

JEFFREY F. ROSEN, District Attorney 

County of Santa Clara, State of California 

By: -------------------------------

TINA NUNES OBER 

Deputy District Attorney 

Attorneys for Plaintiff 

BOB LEE, District Attorney 

::00~~ WiLLIAM·ATKINSON 

Supervising Assistant District Attorney 

Attorneys for Plaintiff 

STEPHEN CARLTON, District Attorney 

County of Shasta, State of California 

By: David J. Irey for 

-------------------------------

STEPHEN CARLTON 

District Attorney 

Attorneys for Plaintiff 

DONALD A DU BAIN, District Attorney 

County of Solano, State of California 

By: ~----------~----------------- CRISELDA B. GONZALEZ 

Senior Deputy District Attorney 

Attorneys for Plaintiff 

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STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION 

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DATED: 

DATED: 

DATED: 

DATED:~ ~ ) o;;;L 

JEFFREY F. ROSEN, District Attorney 

County of Santa Clara, State of California 

By: -T-IN __ A_N_U_N~E~S~O~B~E=R---------------

Deputy District Attorney 

Attorneys for Plaintiff 

BOB LEE, District Attorney 

County of Santa Cruz, State of California 

By: -------------------------------- WILLIAM ATKINSON 

Supervising Assistant District Attorney 

Attorneys for Plaintiff 

STEPHEN CARLTON, District Attorney 

County of Shasta, State of California 

David J. Irey for By: --------------------------------

STEPHEN CARLTON 

District Attorney 

Attorneys for Plaintiff 

DONALD A. DU BAIN, District Attorney 

County of Solano, State of California 

By: 

CRISELDA 

c~/S~ B. GONZAL Z 

Senior Deputy District Attorney 

Attorneys for Plaintiff 

26 

STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION 

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DATED: 

DATED: 

DATED: 

DATED: 

JILL R. RA VITCH, District Attorney 

County of Sonoma, State of California 

By:~\.~ -MA---TT_HE __ W __ T-.C-HE~E_V_E_R __________ _ 

Deputy District Attorney 

Attorneys for Plaintiff 

BIRGIT A. FLADAGER, District Attorney 

County of Stanislaus, State of California 

By: David J. lrey for 

~B-m~G=IT~A-.-F=L_A_D_A~G=E=R------------

District Attorney 

Attorneys for Plaintiff 

CARL V. ADAMS, District Attorney 

County of Sutter, State of California 

By: David J. Irey for 

------------------------------- CARL V. ADAMS 

District Attorney 

Attorneys for Plaintiff 

GREGG COHEN, District Attorney 

County ofTehama, State of California 

By: David J. Irey for 

------------------------------- GREGG COHEN 

District Attorney 

Attorneys for Plaintiff 

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STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION 

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STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION 

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DATED: 

DATED: 

DATED: 

DATED: 

MICHAEL HARPER, District Attorney 

County ofTr· · , ate of California 

District Attorn 

Attorneys for PI · · 

PHILLIP CLINE, District Attorney 

County ofTulare, State of California 

By: 

David J. lrey for 

-R-O~D~N-E=Y~M~.~B~L-A~C~O--------------

Deputy District Attorney 

Attorneys for Plaintiff 

MICHAEL L. KNOWLES, District Attorney 

County ofTuol nne, ate of California 

David J. Irey for 

JEFF W. REISIG, District Attorney 

County ofYolo, State of California 

By: ~~~----~~----~----~------

LARRY BARLL Y 

Supervising Deputy District Attorney 

Attorneys for Plaintiff 

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DATED: 

DATED: y;~ 

DATED: 

DATED: 

MICHAEL HARPER, District Attorney 

County of Trinity, State of California 

By: David J. Irey for 

--------------------------------

MICHAEL HARPER 

District Attorney 

Attorneys for Plaintiff 

PHILLIP CLINE, District Attorney 

County of Tulare, State of California 

BY>-·-·~~ ~-~- ~R~O~D~N~E~Y~M~.~B~L~A~C~O~------------

Deputy District Attorney 

Attorneys for Plaintiff 

MICHAEL L. KNOWLES, District Attorney 

County of Tuolumne, State of California 

By: David J. lrey for 

~M~IC~H~A~E=L~L~.~KN~o=w~LE=s~----------

District Attorney 

Attorneys for Plaintiff 

JEFF W. REISIG, District Attorney 

County ofYolo, State of California 

By: --------------------------------

LARRY BARLL Y 

Supervising Deputy District Attorney 

Attorneys for Plaintiff 

28 

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1 022112 

MICHAEL HARPER, District Attorney 

County ofTrinity, State of California 

By: David J. lrey for 

~M~Ic=H~A~E=L~H=A~RP=E=R~-------------

District Attorney 

Attorneys for Plaintiff 

PHILLIP CLINE, District Attorney 

County of Tulare, State of California 

By: _R_O_D~N~EY~M~.~B-L-A~C-0--------------

Deputy District Attorney 

Attorneys for Plaintiff 

MICHAEL L. KNOWLES, District Attorney 

County of Tuolumne, State of California 

By: David J. frey for 

-M~Ic=H~A~E=L~L-.=KN~o=w=L=E=s-----------

District Attorney 

Attorneys for Plaintiff 

JEFF W. REISIG, District Attorney 

County ofYolo, State of California 

Supervising eputy District Attorney 

Attorneys for Plaintiff 

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FOR DEFENDANT: 

DATED: -----------------

REVIEWED AS TO FORM AND 

CONTENT: 

DATED: 

IT IS SO ORDERED. 

DATED: 

PATRICK McGRATH, District Attorney 

County ofYuba State of California 

By: 

By: 

By: 

David J. lrey for 

Carole A. DeNale 

Senior Vice President and Treasurer 

CVS Pharmacy, Inc. 

--------------------------------- Stephen J. O'Neil 

Sheppard Mullin Richter & Hampton, LLP 

Judge of the Superior Court 

29 

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DATED: 

FOR DEFENDANT: 

DATED: 

REVIEWED AS TO FORM AND 

CONTENT: 

DATED: 

PATRICK McGRATH, District Attomey 

County of Yuba, State of California 

By: 

By: 

David J. Irey for 

------------------------------- PATRICK McGRATH 

District Attorney 

Attorneys for Plaintiff 

Carol A. DeNale 

Senior Vice President and Treasurer 

CVS Pharmacy, Inc. 

\hu L~ o... Lflld TvAjrM 1";t. \he. delL~ 1r i5AdotvcA ·tv ii~AJUtt :}"d.JmefJT. 

lhiL t\udt If ~~nec:tu.l to j .l\IC NoTt u To v~~lVI111.- CovtJ~ OrfiTru'Lt A f-footf\/1 

IT IS SO ORDERED. GllejOI'lj fJC loTillv 9 (}u i.Nl~ (1 jvd_jme~T et~ot 

ki~ 1) f'fice_ Is cAillnTecL '1i) .feAve (VVlu f)N a.ll ofl.vfl 

~wnJ_ 

APR 1 6 2012 DATED: By: 

Judge of the Superior Court 

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022112