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Attorney's Office, District of Colorado. Further, upon payment of any stipulated penalties, the <br />applicable Defendant sha11 provide written notice at the addresses specified in Section XII of this <br />Consent Decree. <br />XI. RESERVATION OF RIGHTS <br />42. United States' Reservation of Rights. The United States reserves all legal and <br />equitable remedies available to enforce the provisions of this Consent Decree. This Consent <br />Decree shall not be construed to limit any right to obtain penalties or injunctive relief available to <br />the United States under other federal, state, or local laws and regulations, except as expressly <br />specified herein. This Consent Decree shall not be construed to limit the right of either <br />Defendant to defend against any claim made by any third party or to seek legal or equitable relief <br />from any third party or from another Defendant based upon or stemming from the alleged <br />activities identified in the United States' Complaint filed in this action. <br />XII. ADDRESSES <br />43. Addresses for Notices Under the Consent Decree. All notices and communications <br />required under this Consent Decree shall be made to the parties through each of the following <br />persons and addresses, or to an alternative individual or entity, 30 days after the name and <br />address of the alternative individual or entity has been sent to all other parties via U.S. Mail, <br />return receipt requested <br />Kenneth M. Champagne, 8ENF-W <br />Section. 404 Enforcement Program <br />United States Environmental Protection Agency <br />Region 8 <br />1595 Wynkoop Street <br />—16— <br />Case 1:16-cv-02008-WYD Document 2 Filed 08/08/16 USDC Colorado Page 18 of 82