Stipulation,Agreement: SYNERGY PROJECT MANAGEMENT, INC. VS. CITY AND COUNTY OF SAN FRANCISCO

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                                Law OFFICE OF BEN ROSENFELD

San Francisco, Ca

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_|RANDOLPH E. DAAR (SBN 88195)

BEN ROSENFELD (SBN 203845)
PIER 5 LAW OFFICES

3330 Geary Blvd., 3rd Floor East. °
San Francisco, CA 94118

Tel: (415) 986-5591

Fax: (415) 421-1331
randolphdaar@yahoo.com

ben.rosenfeld@comeast.net

Attorneys for Plaintiff Synergy Project Management, Inc.

Superior Court of
Goality ofan fren ge

SEP - 7 2022.
CLERK OF THE, COURT
on

» Deputy Cler

<<

SUPERIOR COURT FOR THE STATE OF CALIFORNIA —

COUNTY OF SAN FRANCISCO

SYNERGY PROJECT MANAGEMENT,
INC. Plaintiff,

v.
CITY AND COUNTY OF SAN FRANCISCO,

LONDON BREED, MOHAMMED NURU,
Defendants.

GHILOTT! BROS., INC., Plaintiff,
Vv.
SYNERGY PROJECT MANAGEMENT,

INC., a California Corporation, DOES 1-30,
Defendants. :

SYNERGY PROJECT MANAGEMENT;
Cross-Complainant,

v.

GHILOTTI BROS, INC., ROES 1-20,
Cross-Defendants.

STIPULATION AND [PRO!

Case Nos. CGC-17-560034

and CGC-19-576488, consolidated

ED]
ORDER WIBDRAWING DEFENDANT
CITY AND COUNTY OF SAN

FRANCISCO’S MEMORANDUM OF
COSTS IN EXCHANGE FOR PLAINTIFF
FOREGOING APPEAL

STIPULATION AND Palos} ORDER

Case No. CGC-17-560034Law OFFICE OF BEN ROSENFELD

San Francisco, Ca

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Plaintiff Synergy Project Management, Inc. (“Synergy”) and Defendant City and County
of San Francisco (“the City”) (together, “the parties hereto”), through their undersigned counsel,
hereby agree and stipulate as follows: ,

WHEREAS on June 27, 2022 the Court sustained the City’s demurrer to Synergy’s
opetative Fourth Amended Complaint, and
WHEREAS on July 7, 2022, the Court issued judgment in favor of the City; and -
WHEREAS on July 22,2022, the City filed a prevailing party Memorandum of Costs,
and :

WHEREAS the parties hereto continue to dispute the merits of Synergy’s claims.and ,
causes of action against the City, ,

BEIT RESOLVED that Synergy agrees to waive its right to. appeal the Court’s July 7
2022 Judgment, not appeal, and forever forego any such appeal, in exchange for the City’s :
withdrawal of its July 22, 2022 Memorandum of Costs and waiver of any claimed costs in this
action.

BE IT FURTHER RESOLVED that the parties héreto agree to bear their own attorneys’
fees and costs related to or. arising from this action or the subject-matter thereof, and to. mutually
release one another from any and.all claims or causes of action, monetary or non-monetary,
known or unknown, arising from or in any way related to this action or the subject-matter
thereof, which agreements are binding on the parties hereto, as well as their agents, assigns, and
heirs. ,

This stipulation and agreement is not intended to and does not affect Synergy’s action,

claims, or cause(s) of action against Defendant Ghilotti Bros., Inc.
Respectfully Submitted,

RANDOLPH E. DAAR
BEN ROSENFELD

Zee

Dated: August 29, 2022 By: Ben Rosenfeld
Attorney for Plaintiff Synergy
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STIPULATION AND [PROPOSED] ORDER . CasE No. CGC-17-560034Law OFFICE OF BEN ROSENFELD
San Feancisco, Ca .

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Dated: August 29, 2022

PURSUANT TO STIPULATION, IT IS SOORDERED:

Dated: August -7., 2022

By:

" KRISTINE POPLAWSKI
ARI A. BARUTH
Deputy City Attorneys

Lhe

Ari A. Baruth
Attorney for Defendant City and County of:
San Francisco

Ko OF THE SUPERIOR COURT
“RICHARD ULMER

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STIPULATION AND [PROPOSED] ORDER

CasE No: CGC-17-560034