On February 17, 2016 a
Stipulation,Agreement
was filed
involving a dispute between
The People Of The State Of California,
and
The National Liberty Ship Memorial, Inc.,
for BUSINESS TORT
in the District Court of San Francisco County.
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SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Feb-17-2016 2:06 pm
Case Number: CGC-16-550461
Filing Date: Feb-17-2016 2:04
Filed by: ROSSALY DELAVEGA
Image: 05276617
STIPULATION FOR ENTRY OF JUDGMENT
THE PEOPLE OF THE STATE OF CALIFORNIA VS. THE NATIONAL LIBERTY
SHIP MEMORIAL, INC.
001005276617
Instructions:
Please place this sheet on top of the document to be scanned.Cc 2
District Attorney of San Francisco Superior
JUNE D. CRAVETT, SBN 105094 owe enwatnnn
Managing Assistant Chief District Attorney FEB 17 2016
EVAN H. ACKIRON, SBN 164628
Assistant District Attorney CLERK OF LHe cou
GREGORY M. ALKER, SBN 204838 BY, BP ZOURT
Assistant District Attorney ct Deon is;
732 Brannan Street
San Francisco, California 94103
Telephone: (415) 551-9552
Attorneys for Plaintiff,
The People of the State of California
GEORGE GASCON, SBN 182345 F I L E. D
of lia
SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
CGC 16-550 461
THE PEOPLE OF THE STATE OF Case No.
CALIFORNIA,
STIPULATION FOR ENTRY OF
Plaintiff, JUDGMENT AND PERMANENT
INJUNCTION
vs.
NATIONAL LIBERTY SHIP MEMORIAL,
INC., a California Corporation.
Defendant.
Plaintiff, the People of the State of California, represented by George Gascén, the District
Attorney of the City and County of San Francisco (“District Attorney”) and Defendant National
Liberty Ship Memorial Inc., (“Defendant”), represented by Rex Clack of Sterling, Clack & Russo,
hereby enter into this Stipulation for Entry of Judgment and Permanent Injunction as follows:
1. Defendant waives service of a summons and complaint in this action.
2. The proposed Stipulated Judgment and Permanent Injunction, a copy of which is
attached hereto as Exhibit 1 and incorporated herein by reference, may be rendered and entered as
set forth herein, without the taking of proof and without trial or adjudication of any issue of fact or
law, and without the Stipulated Judgment and Permanent Injunction constituting evidence or an
STIPULATION FOR ENTRY OF JUDGMENT AND PERMANENT INJUNCTION - 1Oo wend DH HA FF Ww NH
yoy Re YR RN KD Fe ee ee ee ee
aA A BBN FP SO eB NQ DH FF WN = SO
Cc >
admission by Defendant regarding any issue of fact or law alleged in the Complaint, and without
Defendant admitting any liability.
3. The parties expressly stipulate and agree that the Stipulated Judgment and Permanent
Injunction is entered into for the purpose of resolving disputed claims without any admission of
liability or wrongdoing on the part of Defendant.
4. Defendant represents and warrants that it is the proper party to the Stipulated
Judgment and Permanent Injunction.
5. Defendant represents and warrants that its execution and delivery of this Stipulation
for Entry of Judgment and Permanent Injunction is its free and voluntary act and that the
Stipulation for Entry of Judgment and Permanent Injunction and the Stipulated Judgment and
Permanent Injunction are the result of good faith settlement negotiations.
6. The parties represent and warrant that they will implement the terms of the Stipulated
Judgment and Permanent Injunction in good faith.
7. District Attorney may submit the Stipulated Judgment and Permanent Injunction to
any judge or commissioner of the Superior Court of the State of California for approval and
signature, based upon this Stipulation for Entry of Judgment and Permanent Injunction, during the
Court’s ex parte calendar or on any other ex parte basis, without notice to or any appearance by
Defendant, which notice and right to appear Defendant hereby waives.
8. Defendant waives any right to appeal, to attempt to set aside or vacate, or otherwise
attack, directly or collaterally, the Stipulated Judgment and Permanent Injunction entered pursuant
to this Stipulation or any provision contained therein.
9. Defendant will pay any fees charged by the Superior Court associated with the filing
of the Stipulation for Entry of Judgment and Permanent Injunction and any other court fee
associated with its appearance in this action.
10. This Stipulation for Entry of Judgment and Permanent Injunction may be executed in
counterparts and on multiple signature pages.
IT IS SO STIPULATED.
STIPULATION FOR ENTRY OF JUDGMENT AND PERMANENT INJUNCTION - 2oo ND MW FF WN =
Nw NY NY N NN NY fF SF SF Fe SF Fe EF Fe Se
nav Bw NH fF SG BO Oe NQ DH FF YW NS S&S
Cc
DATED: February!4, 2016
DATED: February 7, 2016
WO)
GEORGE GASCO.
District Attorney, City and County of San Francisco
BY:
“Y ALKER'
Assistant District Attorney
NATIONAL LIBERTY MEMORIAL SHIP, INC.
BY:
hairman of the Board Jeffrey Dickow
APPROVED AS TO FORM AND CONTENT
DATED: February 2016
STERLING, CLACK & RUSSO
ab
Attorneys for National Liberty Memorial Ship, Inc.
STIPULATION FOR ENTRY OF JUDGMENT AND PERMANENT INJUNCTION - 3
Document Filed Date
February 17, 2016
Case Filing Date
February 17, 2016
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SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Feb-17-2016 2:06 pm Case Number: CGC-16-550461 Filing Date: Feb-17-2016 2:04 Filed by: ROSSALY DELAVEGA Image: 05276617 STIPULATION FOR ENTRY OF JUDGMENT THE PEOPLE OF THE STATE OF CALIFORNIA VS. THE NATIONAL LIBERTY SHIP MEMORIAL, INC. 001005276617 Instructions: Please place this sheet on top of the document to be scanned.Cc 2 District Attorney of San Francisco Superior JUNE D. CRAVETT, SBN 105094 owe enwatnnn Managing Assistant Chief District Attorney FEB 17 2016 EVAN H. ACKIRON, SBN 164628 Assistant District Attorney CLERK OF LHe cou GREGORY M. ALKER, SBN 204838 BY, BP ZOURT Assistant District Attorney ct Deon is; 732 Brannan Street San Francisco, California 94103 Telephone: (415) 551-9552 Attorneys for Plaintiff, The People of the State of California GEORGE GASCON, SBN 182345 F I L E. D of lia SUPERIOR COURT OF THE STATE OF CALIFORNIA CITY AND COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION CGC 16-550 461 THE PEOPLE OF THE STATE OF Case No. CALIFORNIA, STIPULATION FOR ENTRY OF Plaintiff, JUDGMENT AND PERMANENT INJUNCTION vs. NATIONAL LIBERTY SHIP MEMORIAL, INC., a California Corporation. Defendant. Plaintiff, the People of the State of California, represented by George Gascén, the District Attorney of the City and County of San Francisco (“District Attorney”) and Defendant National Liberty Ship Memorial Inc., (“Defendant”), represented by Rex Clack of Sterling, Clack & Russo, hereby enter into this Stipulation for Entry of Judgment and Permanent Injunction as follows: 1. Defendant waives service of a summons and complaint in this action. 2. The proposed Stipulated Judgment and Permanent Injunction, a copy of which is attached hereto as Exhibit 1 and incorporated herein by reference, may be rendered and entered as set forth herein, without the taking of proof and without trial or adjudication of any issue of fact or law, and without the Stipulated Judgment and Permanent Injunction constituting evidence or an STIPULATION FOR ENTRY OF JUDGMENT AND PERMANENT INJUNCTION - 1Oo wend DH HA FF Ww NH yoy Re YR RN KD Fe ee ee ee ee aA A BBN FP SO eB NQ DH FF WN = SO Cc > admission by Defendant regarding any issue of fact or law alleged in the Complaint, and without Defendant admitting any liability. 3. The parties expressly stipulate and agree that the Stipulated Judgment and Permanent Injunction is entered into for the purpose of resolving disputed claims without any admission of liability or wrongdoing on the part of Defendant. 4. Defendant represents and warrants that it is the proper party to the Stipulated Judgment and Permanent Injunction. 5. Defendant represents and warrants that its execution and delivery of this Stipulation for Entry of Judgment and Permanent Injunction is its free and voluntary act and that the Stipulation for Entry of Judgment and Permanent Injunction and the Stipulated Judgment and Permanent Injunction are the result of good faith settlement negotiations. 6. The parties represent and warrant that they will implement the terms of the Stipulated Judgment and Permanent Injunction in good faith. 7. District Attorney may submit the Stipulated Judgment and Permanent Injunction to any judge or commissioner of the Superior Court of the State of California for approval and signature, based upon this Stipulation for Entry of Judgment and Permanent Injunction, during the Court’s ex parte calendar or on any other ex parte basis, without notice to or any appearance by Defendant, which notice and right to appear Defendant hereby waives. 8. Defendant waives any right to appeal, to attempt to set aside or vacate, or otherwise attack, directly or collaterally, the Stipulated Judgment and Permanent Injunction entered pursuant to this Stipulation or any provision contained therein. 9. Defendant will pay any fees charged by the Superior Court associated with the filing of the Stipulation for Entry of Judgment and Permanent Injunction and any other court fee associated with its appearance in this action. 10. This Stipulation for Entry of Judgment and Permanent Injunction may be executed in counterparts and on multiple signature pages. IT IS SO STIPULATED. STIPULATION FOR ENTRY OF JUDGMENT AND PERMANENT INJUNCTION - 2oo ND MW FF WN = Nw NY NY N NN NY fF SF SF Fe SF Fe EF Fe Se nav Bw NH fF SG BO Oe NQ DH FF YW NS S&S Cc DATED: February!4, 2016 DATED: February 7, 2016 WO) GEORGE GASCO. District Attorney, City and County of San Francisco BY: “Y ALKER' Assistant District Attorney NATIONAL LIBERTY MEMORIAL SHIP, INC. BY: hairman of the Board Jeffrey Dickow APPROVED AS TO FORM AND CONTENT DATED: February 2016 STERLING, CLACK & RUSSO ab Attorneys for National Liberty Memorial Ship, Inc. STIPULATION FOR ENTRY OF JUDGMENT AND PERMANENT INJUNCTION - 3