CONSENT DECREE AGREEMENT KEY TERMSConsent Decree Agreement • June 19th, 2017
• Within 30 days of this Agreement’s execution, the Parties shall jointly move in City of Santa Monica v. United States of America, et al., Case No. 13-CV-8046-JFW (VBKx) (C.D. Cal.), for entry of this Agreement as a Consent Decree and for a stay of the the litigation pending the decision on the Consent Decree. Also within 30 days of this Agreement, the Parties shall jointly move to stay City of Santa Monica v. Federal Aviation Administration, No. 16-72827, (9th Cir.), pending the entry of the Consent Decree. Within 14 days of the entry of the Consent Decree, the City shall dismiss with prejudice City of Santa Monica v. Federal Aviation Administration, No. 16- 72827, (9th Cir.). Furthermore, the Parties agree that entry of the Consent Decree shall resolve all pending disputes at issue in In re Compliance with Federal Obligations by the City of Santa Monica, FAA NO. 16-16-13 (U.S. Dep’t of Transp., Fed. Aviation Admin.), and that the FAA shall therefore dismiss the NOI.
