CONSENT JUDGMENT

OTIS D. WRIGHT, II, District Judge.

Plaintiff THOMAS E. PEREZ, Secretary of Labor, United States Department of Labor ("Secretary" or "Plaintiff") and defendants SKYWAY INC., a California corporation ("Skyway"), SKYWAY GROUP OF COMPANIES INC., a California corporation ("Skyway Group"), RAJINDER BHANGU and DAVID BHANGU (hereafter collectively referred to as the "Defendants") have agreed to resolve the matters in controversy in this civil action and consent to the entry of this Consent Judgment in accordance herewith:

A. On September 28, 2015, the Secretary filed a Complaint to enforce his Final Order, entered In the Matter of Herbert Alexander/Skyway Trucking School, OSHA Case No. 9-3290-13-113, against the Defendants pursuant to the employee protection provisions of the Surface Transportation Assistance Act of 1982 ("STAA"), 49 U.S.C. § 31105 and its implementing regulations, 29 C.F.R. § 1978.100, et seq. [Document 1]. A copy of the Final Order is attached hereto as Exhibit 1, and it is incorporated herein by this reference.

B. The Secretary filed a First Amended Complaint against the Defendants on March 1, 2016 [Document 40], and each of the Defendants hereby acknowledges service of process.

C. Skyway Group answered the First Amended Complaint on March 23, 2016 [Document 47].

D. A Default by Clerk was entered against Skyway on March 29, 2016 [Document 50].

E. In lieu of answering the First Amended Complaint and asserting any defenses thereto, defendants RAJINDER BHANGU and DAVID BHANGU, along with Skyway and Skyway Group, have each agreed to the terms of this Consent Judgment to settle this proceeding and to settle and incorporate into the Consent Judgment the terms of the Settlement Agreement entered in the related administrative law case before the Office of Administrative Law Judges, U.S. Department of Labor, entitled In the Matter of Herbert Alexander v. Skyway Trucking School, OALJ Case No. 2016-STA-00011 (hereafter the "Related Action"). A true and correct copy of the Settlement Agreement entered in the Related Action is attached hereto as Exhibit 2, and it is incorporated herein by this reference.

F. The Secretary and Defendants waive Findings of Fact and Conclusions of Law, and agree to the entry of this Consent Judgment in settlement of this action, without further contest.

It is therefore, upon motion of the attorneys for the Secretary, and for cause shown,

IT IS ORDERED, ADJUDGED, AND DECREED that the defendants SKYWAY INC., SKYWAY GROUP OF COMPANIES INC., RAJINDER BHANGU and DAVID BHANGU be, and they hereby are, permanently enjoined and restrained from violating the Secretary's Final Order.

IT IS FURTHER ORDERED that in lieu of reinstatement of Herbert Alexander to his former position with Skyway as required by the Final Order, and in settlement of this proceeding and the Related Action, Defendants jointly and severally shall pay Herbert Alexander the total sum of $15,000.00 ("Settlement Amount") as follows:

1. The initial payment to Herbert Alexander of $5,000.00 shall be delivered to the law office of counsel for the Secretary by the close of business on May 27, 2016.

2. Thereafter, commencing on June 15, 2016, and on the fifteenth (15th) day of each month until and including March 15, 2017, a monthly payment of $1,000.00 shall be delivered to the Complainant at the following address:

IT IS FURTHER ORDERED that interest from the date of judgment at the legal rate until paid in full and costs shall accrue pursuant to 28 U.S.C. § 1920, but all accrued interest shall be waived if the Settlement Amount is paid in full by the Defendants, as agreed to above, on or before March 15, 2017.

IT IS FURTHER ORDERED that each party shall bear its own fees and other expenses incurred by such party in connection with any stage of this proceeding, including but not limited to attorneys' fees, which may be available under the Equal Access to Justice Act, as amended; and

IT IS FURTHER ORDERED that this Court shall retain jurisdiction of this action for purposes of enforcing compliance with the terms of this Consent Judgment.

Entry of this Consent Judgment is hereby consent to by all parties.