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of this Consent Decree; <br />C. Defendants have paid all penalties and other monetary obligations hereunder <br />and no penalties or other monetary obligations are outstanding or awed to the United States; <br />D. There are no unresolved matters subject to dispute resolution pending <br />pursuant to the dispute resolution provisions of this Consent Decree; and <br />E. No enforcement action under this Consent Decree is pending. <br />49. Joint Stipulation for Termination or Dispute Resolution. If the United States agrees <br />that the requirements of Paragraph 48 are satisfied, the parties shall submit, for the Court's <br />approval, a joint stipulation terminating the Consent Decree. If the United States does not agree <br />that the requirements of Paragraph 48 are satisfied, the Defendants may invoke the provisions of <br />Section VIII (Dispute Resolution) and the Consent Decree shall remain in effect pending <br />resolution of the dispute by the parties, or, ultimately, by the Court. In any dispute regarding <br />termination of this Consent Decree, Defendants shall bear the burden of proving by a <br />preponderance of the evidence that all conditions required for termination of this Consent Decree <br />are satisfied. <br />S0. Entire Agreement. This Consent Decree constitutes the final, complete and <br />exclusive agreement and understanding among the parties with respect to the settlement <br />embodied in this Consent Decree. The parties acknowledge that there are no representations, <br />agreements or understandings relating to the settlement other than those expressly contained in <br />this Consent Decree. <br />51. Authority to Execute Consent Decree and Bind Partv. By signing this Consent <br />Decree, each signatory warrants that the signatory has full authority to act on behalf of the party <br />—19— <br />Case 1:16-cv-02008-WYD Document 2 Filed 08/08/16 USDC Colorado Page 21 of 82