Case 1:17-cv DAD-SKO Document 37-1 Filed 03/19/18 Page 1 of 8

Similar documents
Plaintiff, Defendants.

Case: 1:17-cv TSB Doc #: 4-1 Filed: 03/15/18 Page: 1 of 10 PAGEID #: 193. Plaintiffs, THE HONORABLE TIMOTHY S. BLACK. Defendants.

Case 1:18-cv LY Document 43 Filed 09/17/18 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

Case 4:17-cv JLK Document 29 Entered on FLSD Docket 02/13/2018 Page 1 of 5

GENERAL RELEASE. WHEREAS, Theresa M. Petrello of Manchester, New Hampshire (hereinafter,

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION SETTLEMENT AGREEMENT

SETTLEMENT AGREEMENT

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA THE PARTIES AND THEIR ATTORNEYS OF RECORD HEREBY SUBMIT THE

SETTLEMENT AGREEMENT AND GENERAL RELEASE. WHEREAS, Alfredo Valentin of Manchester, New Hampshire (hereinafter, Plaintiff )

Case 1:10-cv PLF Document 17 Filed 08/04/11 Page 1 of 4 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Case 1:18-cv JGK Document 26 Filed 02/21/19 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA Harrisburg Division --ELECTRONICALLY FILED--

Case 3:15-cv VAB Document 46 Filed 05/20/16 Page 1 of 52

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ROME DIVISION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 1:11-CV JGK PROOF OF CLAIM AND RELEASE FORM

Case Doc 1 Filed 03/24/11 Entered 03/24/11 16:24:26 Desc Main Document Page 1 of 8

stipulated that each of the above parties shall bear its own costs and fees.

Case 3:15-cv BRM-LHG Document 82-1 Filed 09/27/17 Page 1 of 80 PageID: 1050 EXHIBIT A

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PASCO COUNTY, FLORIDA CIVIL DIVISION

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

scc Doc 928 Filed 03/12/12 Entered 03/12/12 18:37:05 Main Document Pg 1 of 8

Case 1:14-cv KMW Document 14 Entered on FLSD Docket 09/08/2014 Page 1 of 7

SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS. This Settlement and Mutual Release Agreement (this Agreement ) is made and entered into

Gold Leaf Overseas SA 4128 et al v. Castro et al Doc. 41. Case 2:13-cv RCJ-CWH Document 39 Filed 08/03/15 Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WISCONSIN GREEN BAY DIVISION ) ) ) ) ) ) ) ) ) ) )

Case CSS Doc 783 Filed 09/07/18 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

Case Document 1075 Filed in TXSB on 12/20/16 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WISCONSIN. v. Case No. 01-C-0928 SETTLEMENT AGREEMENT INDEX TO SECTIONS

Case 1:10-cv EGS Document 44 Filed 03/15/12 Page 1 of 5 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA

SETTLEMENT AND RELEASE AGREEMENT

LAWRENCE COUNTY MUNICIPAL COURT LOCAL RULES RULE ONE

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Case 3:17-cv EMC Document 49 Filed 08/26/18 Page 1 of 15

SHAKER HEIGHTS MUNICIPAL COURT LOCAL RULES OF PRACTICE

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. Case No.:

SETTLEMENT AND RELEASE AGREEMENT. THIS SETTLEMENT AND RELEASE AGREEMENT ( Agreement ) is

Case MBK Doc 635 Filed 01/16/15 Entered 01/22/15 08:05:30 Desc Main Document Page 1 of 5

SETTLEMENT AGREEMENT AND RELEASE. into by and between Sandra G. Myrick ("Myrick") and the North Carolina Administrative Office

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ROME DIVISION. Plaintiffs, ) CIVIL ACTION FILE. v. ) NO.

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY NOTICE OF CLASS ACTION AND PROPOSED SETTLEMENT

Case 1:16-cv JDB Document 33 Filed 12/28/16 Page 1 of 9 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JOINT STIPULATION OF DISMISSAL OF DEFENDANT AIR FRANCE-KLM WITHOUT PREJUDICE [F.R.C.P. 4141(a)(1)(A)(ii)]

In the United States Court of Federal Claims

Case: 2:13-cv CMV Doc #: 92 Filed: 11/14/18 Page: 1 of 6 PAGEID #: 812 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

LOCAL RULES OF THE COURT OF APPEAL, FOURTH CIRCUIT SUPPLEMENTING AND/OR SUPERSEDING UNIFORM RULES OF LOUISIANA COURTS OF APPEAL

SETTLEMENT AGREEMENT AND RELEASE

(e) Appearance of Attorney. An attorney may appear in a proceeding in any of the following ways:

shl Doc 36 Filed 05/15/12 Entered 05/15/12 17:26:47 Main Document Pg 1 of 5

EEOC v. Pacific Airport Services, Inc.,

mew Doc 2483 Filed 02/09/18 Entered 02/09/18 11:14:51 Main Document Pg 1 of 14

Case 1:13-cv GJQ Doc #12 Filed 04/16/14 Page 1 of 7 Page ID#34 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Case Document 496 Filed in TXSB on 04/04/16 Page 1 of 3

Case ast Doc 263 Filed 10/14/14 Entered 10/14/14 15:36:10. (Jointly Administered)

Case 1:14-cv JBW-LB Document 116 Filed 04/05/16 Page 1 of 9 PageID #: CV-1 199

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

I. ANSWER. COMES NOW Defendant IMPULSE MEDIA GROUP, INC. in the above-captioned

Case: LTS Doc#:111 Filed:05/25/17 Entered:05/25/17 13:40:50 Document Page 1 of 6

Case 1:16-cv PBS Document 32 Filed 12/12/16 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS EASTERN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ROME DIVISION

PROOF OF CLAIM AND RELEASE

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ROME DIVISION

alg Doc 4107 Filed 06/21/13 Entered 06/21/13 15:25:45 Main Document Pg 1 of 3. Chapter 11. Debtors.

Case: 1:12-cv Document #: 29-1 Filed: 07/30/13 Page 2 of 13 PageID #:365

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF KANSAS. IN RE: ) ) Case No MISSION GROUP KANSAS, INC. ) ) Chapter 7 Debtor.

UNITED STATES BANKRUPTCY COURT DISTRICT OF SOUTH CAROLINA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) NOTICE OF REMOVAL

EXHIBIT A SETTLEMENT AGREEMENT

Case 1:02-cv JR Document 78 Filed 01/29/2009 Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:09-cv TWT Document 3 Filed 03/24/2009 Page 1 of 10

SETTLEMENT AGREEMENT AND RELEASE. This settlement agreement was executed by and between Plaintiffs Amelia Thompson

Case 1:12-cv RPM Document 8 Filed 07/11/12 USDC Colorado Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) )

vs. ) Case No. CIV Pursuant to [insert Settlement Act citation] (hereinafter the Settlement Act ),

SETTLEMENT AGREEMENT, COVENANT NOT TO SUE AND RELEASE THIS SETTLEMENT AGREEMENT, COVENANT NOT TO SUE AND

Case 2:16-cv JNP Document 105 Filed 08/17/17 Page 1 of 106

SETTLEMENT AGREEMENT AND RELEASE OF CLAIMS

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

SETTLEMENT AGREEMENT AND RELEASE

Case 1:12-cv VEC Document Filed 03/26/15 Page 1 of 7 EXHIBIT A-3

Case pwb Doc 281 Filed 10/28/16 Entered 10/28/16 13:58:15 Desc Main Document Page 1 of 12

Case Document 162 Filed in TXSB on 11/07/18 Page 1 of 6

SETTLEMENT AGREEMENT AND GENERAL RELEASE

tjt Doc 2391 Filed 10/21/14 Entered 10/21/14 16:40:26 Page 1 of 5

Case MBK Doc 540 Filed 09/15/14 Entered 09/17/14 13:25:19 Desc Main Document Page 1 of 7

Case pwb Doc 1097 Filed 11/26/14 Entered 11/26/14 10:26:12 Desc Main Document Page 1 of 9

Case 3:17-cv JAG Document 41 Filed 02/21/18 Page 1 of 8 PageID# 258

Case 9:15-cv KAM Document 37 Entered on FLSD Docket 06/03/2015 Page 1 of 7

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Case 3:12-cv Document 99 Filed in TXSD on 04/07/14 Page 1 of 9

Office of the Attorney General State of Florida Department of Legal Affairs

Case 2:15-cv LDD Document 54 Filed 12/12/16 Page 1 of 12 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA ASHEVILLE DIVISION

Case EPK Doc 1019 Filed 03/06/15 Page 1 of 16

Case 3:07-cv SI Document 25 Filed 11/26/2007 Page 1 of 7

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Transcription:

Case :-cv-00-dad-sko Document - Filed 0// Page of 0 0 TRAVIS C. BARHAM, Georgia Bar No. ALLIANCE DEFENDING FREEDOM 000 Hurricane Shoals Road NE, Ste. D-00 Lawrenceville, Georgia 00 Telephone: (0) 0 Facsimile: (0) tbarham@adflegal.org MICHAEL L. RENBERG, California Bar No. PARICHAN, RENBERG & CROSSMAN 00 East Shaw Avenue, # Fresno, California 0 Telephone: () 00 Facsimile: () 0 mrenberg@prcelaw.com Attorneys for Plaintiffs DAVID J. FRANKENBERGER, #0 MICHAEL E. LEHMAN, # ERICKSEN ARBUTHNOT 0 West Shaw Avenue, Suite 0 Fresno, California Telephone: () 00 Facsimile: () 0 dfrankenberger@ericksenarbuthnot.com mlehman@ericksenarbuthnot.com Attorneys for Defendant FRESNO STATE STUDENTS FOR LIFE, et al., v. WILLIAM GREGORY THATCHER, UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA Plaintiffs, Defendant. Case No. :-CV-00-DAD-SKO SETTLEMENT AGREEMENT & RELEASE This Settlement Agreement & Release (the Agreement ) is made and entered into by and between Plaintiffs Fresno State Students for Life, Bernadette Tasy, and Jesus Herrera and Defendant William Gregory Thatcher to resolve the above-captioned lawsuit. SETTLEMENT AGREEMENT & RELEASE

Case :-cv-00-dad-sko Document - Filed 0// Page of 0 0 RECITALS. On May, 0, Plaintiffs filed a Verified Complaint in the United States District Court for the Eastern District of California in a case styled Fresno State Students for Life v. Thatcher, No. :-CV-00-DAD-SKO (hereinafter, the Litigation ), seeking injunctive, declaratory, and monetary relief for the violation of their rights under the First and Fourteenth Amendments to the United States Constitution.. In their Verified Complaint, Plaintiffs challenged Defendant Thatcher s actions in interfering with and erasing their constitutionally protected expression on the campus of California State University, Fresno ( Fresno State University or University ) on May, 0.. On November, 0, the parties and their counsel participated in a settlement conference that resulted in an agreement to resolve this case.. On December, 0, Defendant Thatcher refused to complete the First Amendment training session that was scheduled for that date and that was a component of the November, 0 agreement. See Notice Regarding Efforts to Complete Settlement Agreement, Dec., 0, ECF No. ; Pls. Uncontested Mot. for Extension of Time to File Dispositive Documents, Jan., 0, ECF No.. Thereafter, the parties negotiated additional terms to resolve the issues his actions raised. Hence, this document sets forth all agreements made between the parties to resolve the disputes between them.. In order to avoid the expense, risk, and cost of further proceedings in this Litigation, and without any admission of liability upon the claims asserted in the Litigation, the parties desire to resolve all claims asserted in the Litigation in accordance with the terms and conditions set forth in this Agreement. AGREEMENT Now therefore, Plaintiffs and Defendants agree as follows: SETTLEMENT AGREEMENT & RELEASE

Case :-cv-00-dad-sko Document - Filed 0// Page of 0 0. Defendant Thatcher has agreed: a. To pay Mr. Herrera the sum of one thousand dollars ($,000.00) via a check or draft payable to Mr. Herrera that will be delivered to Plaintiffs counsel; b. To pay Miss Tasy the sum of one thousand dollars ($,000.00) via a check or draft payable to Miss Tasy that will be delivered to Plaintiffs counsel; c. To pay Alliance Defending Freedom ( ADF ) the sum of twenty-five thousand, nine hundred, ninety-six dollars, and sixty-three cents ($,.) (i.e., $,000 to resolve Plaintiffs claims for attorneys fees and costs and $0,. to reimburse ADF for the costs and fees associated with the December, 0 First Amendment training session) via a check or draft payable to Alliance Defending Freedom that will be delivered to Plaintiffs counsel; d. To agree to the entry of an injunctive order, which the Court has since entered (see Order Granting Joint Motion for Stipulated Injunctive Relief, Nov., 0, ECF No. ); and e. To complete a training session on First Amendment rights, lasting no longer than two hours, presented by Alliance Defending Freedom, subject to the following conditions: i. Defendant Thatcher will attend the training session at 0:00 a.m. (Pacific Standard Time) on February, 0 at the office of Mr. Lehman; ii. Mr. Lehman will certify that Defendant Thatcher was present for the entire two hours and that the training was visible and audible for Defendant Thatcher for the entire two hours (i.e., that no one turned off the video or muted the sound); and iii. ADF will audio and video record the training session. (Defendant Thatcher completed this training, which lasted approximately an hour and a half, on the date and at the time given above.). Plaintiffs have agreed: SETTLEMENT AGREEMENT & RELEASE

Case :-cv-00-dad-sko Document - Filed 0// Page of 0 0 a. To dismiss this Litigation with prejudice within ten (0) days after Defendant Thatcher completes all of his obligations under this Agreement; b. To release and discharge forever Defendant Thatcher from all claims that were raised or could have been raised in the Litigation that arose from, concerned, or were in any way related to the facts set forth in Plaintiffs Verified Complaint.. By entering into this Agreement, Defendant is not admitting liability, and this Agreement shall never be treated as an admission of liability or responsibility at any time for any purpose.. The provisions of Section of the Civil Code of the State of California are hereby expressly waived, and the parties understand that this section provides: A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which if known by him must have materially affected his settlement with the debtor.. In the event legal action is brought to enforce any provision of this Agreement, the prevailing party shall be entitled to recover its reasonable attorneys fees and costs of the suit.. For the parties protection, California law requires the following to appear in this Agreement: Any person who knowingly presents false or fraudulent claim for payment of a loss is guilty of a crime and may be subject to fines and confinement in state prison.. This Agreement may be executed in one or more counterparts, each if which shall be deemed an original. The execution of this Agreement by signature transmitted by facsimile or other electronic means shall be as fully enforceable as an original signature.. The parties have all been fully advised by their respective counsel as to the meaning and effect of this Agreement. SETTLEMENT AGREEMENT & RELEASE

Case :-cv-00-dad-sko Document - Filed 0// Page of ĥ ŕ ź? ï ï İ ń ï ģ? Scanned by CamScanner

Case :-cv-00-dad-sko Document - Filed 0// Page of Scanned by CamScanner

Case :-cv-00-dad-sko Document - Filed 0// Page of

Case :-cv-00-dad-sko Document - Filed 0// Page of

Case :-cv-00-dad-sko Document Filed 0// Page of 0 0 TRAVIS C. BARHAM, Georgia Bar No. ALLIANCE DEFENDING FREEDOM 000 Hurricane Shoals Road NE, Ste. D-00 Lawrenceville, Georgia 00 Telephone: (0) 0 Facsimile: (0) tbarham@adflegal.org MICHAEL L. RENBERG, California Bar No. PARICHAN, RENBERG & CROSSMAN 00 East Shaw Avenue, # Fresno, California 0 Telephone: () 00 Facsimile: () 0 mrenberg@prcelaw.com Attorneys for Plaintiffs DAVID J. FRANKENBERGER, #0 MICHAEL E. LEHMAN, # ERICKSEN ARBUTHNOT 0 West Shaw Avenue, Suite 0 Fresno, California Telephone: () 00 Facsimile: () 0 dfrankenberger@ericksenarbuthnot.com mlehman@ericksenarbuthnot.com Attorneys for Defendant FRESNO STATE STUDENTS FOR LIFE, et al., v. WILLIAM GREGORY THATCHER, UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA Plaintiffs, Defendant. Case No. :-CV-00-DAD-SKO STIPULATION OF VOLUNTARY DISMISSAL Pursuant to the terms of the settlement agreement attached as Exhibit A to this stipulation, Plaintiffs and Defendant, by and through counsel, stipulate to the voluntary dismissal with prejudice of all claims brought in Plaintiffs Verified Complaint in the above-captioned case under FED. R. CIV. P. (a)()(a)(ii). JOINT MOTION FOR STIPULATED INJUNCTIVE RELIEF

Case :-cv-00-dad-sko Document Filed 0// Page of 0 Respectfully submitted this th day of March, 0, /s/ Travis C. Barham TRAVIS C. BARHAM* Georgia Bar No. ALLIANCE DEFENDING FREEDOM 000 Hurricane Shoals Road NE, Ste. D-00 Lawrenceville, Georgia 00 Telephone: (0) 0 Facsimile: (0) tbarham@adflegal.org MICHAEL L. RENBERG California Bar No. PARICHAN, RENBERG & CROSSMAN 00 East Shaw Avenue, # Fresno, California 0 Telephone: () 00 Facsimile: () 0 mrenberg@prcelaw.com * Admitted pro hac vice. Attorneys for Plaintiffs /s/ Michael E. Lehman (with consent) DAVID J. FRANKENBERGER, #0 MICHAEL E. LEHMAN, # ERICKSEN ARBUTHNOT 0 West Shaw Avenue, Suite 0 Fresno, California Telephone: () 00 Facsimile: () 0 dfrankenberger@ericksenarbuthnot.com mlehman@ericksenarbuthnot.com Attorneys for Defendant 0 JOINT MOTION FOR STIPULATED INJUNCTIVE RELIEF

Case :-cv-00-dad-sko Document Filed 0// Page of 0 CERTIFICATE OF SERVICE I hereby certify that on the th day of March, 0, I electronically filed a true and accurate copy of the foregoing document with the Clerk of Court using the CM/ECF system, which automatically sends an electronic notification to the following attorneys of record: DAVID J. FRANKENBERGER, #0 MICHAEL E. LEHMAN, # ERICKSEN ARBUTHNOT 0 West Shaw Avenue, Suite 0 Fresno, California Telephone: () 00 Facsimile: () 0 dfrankenberger@ericksenarbuthnot.com mlehman@ericksenarbuthnot.com Attorneys for Defendant Respectfully submitted on this the th day of March, 0. /s/ Travis C. Barham TRAVIS C. BARHAM Attorney for Plaintiffs 0 JOINT MOTION FOR STIPULATED INJUNCTIVE RELIEF