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further consent to and will not contest the authority of the United States to issue this Consent Order or to implement or enforce its terms . 3 . The Parties agree that the actions undertaken in accordance with this Consent Order do not constitute an admission of any liability by the City or any Respondent. The City and the Respondents do not admit, and retain the right to controvert in any subsequent proceedings other than proceedings to implement or enforce this Consent Order, the validity of the Statement of Facts or Determinations contained in Sections IV and V . respectively, of this Consent Order. II. STATEMENT OF PURPOSE 4. By entering into this Consent Order, the mutual objectives of the Parties are : a. to avoid the potential for difficult, prolonged and complicated litigation between the City, the Respondents and/or EPA ; b , to reach a final settlement between EPA and the Respondents with respect to the Site pursuant to Section 122(g) of CERCLA, 42 U . S . C . § 9622(g) , that allows each Respondent to make a cash payment, including a premium, to resolve each Respondent' s alleged civil liability under Sections 106 and 107 of CERCLA, 42 U . S .C . § 9606 and 9607 , for injunctive relief with regard to the Site and for response costs incurred or to be incurred at or in connection with the Site, subject to reservations of rights contained herein ; co to reach a final settlement between EPA and the City with respect to the Site pursuant to Section 122(h) of CERCLA, 42 U. S . C. § 9622(h), and the authority of the Attorney General to compromise and settle claims of the United States , that allows the City to resolve its alleged civil liability under Sections 106 and 107 of CERCLA, 42 U . S .C . § § 9606 and 9607 , for injunctive relief with regard to the Site and for response costs incurred or to be incurred at or in connection with the Site, subject to reservations of rights contained herein ; do to simplify any remaining administrative and judicial enforcement activities concerning the Site by eliminating a substantial number of potentially responsible parties from further involvement at the Site , thereby reducing litigation relating to the Site ; e. to obtain a final settlement among the Parties for the Respondents ' fair share of response costs incurred and to be incurred at or in connection with the Site by the EPA Hazardous Substance Superfund and by private and governmental parties , and to provide for full and complete contribution protection for the Respondents, including protection from claims among the Parties , with regard to the Site 2