Contract analysis

1. Dismissal of Plaintiff's Complaint. All causes of action asserted in Plaintiff Gavin Aldrich's Complaint, filed on December 9, 2022, including but not limited to the first cause of action for Wrongful Termination in Violation of Public Policy, the second cause of action for Breach of Contract, the third cause of action for Breach of the Implied Covenant of Good Faith and Fair Dealing, the fourth cause of action fo

2. Dismissal of Defendant's Amended Cross-Complaint. All causes of action asserted in Defendant and Cross-Complainant Aurelius Media Americas Inc.'s Amended Cross-Complaint, filed on April 5, 2023 (and the original Cross-Complaint filed on January 20, 2023, to the extent not superseded), are hereby dismissed with prejudice in their entirety. This dismissal extends to all claims for relief, whether for damages, injunc

3. Costs and Attorneys' Fees. Each Party shall bear its own costs and attorneys' fees incurred in connection with this action, including but not limited to filing fees, motion fees, deposition costs, costs of transcription, expert witness fees and costs, costs of document production and review, service of process fees, and attorneys' fees of every kind and nature. No Party shall seek to recover costs or attorneys' fe

4. Reservation of Jurisdiction Under Code of Civil Procedure Section 664.6. Notwithstanding the dismissal of this action with prejudice, the Court shall retain jurisdiction over the Parties to enforce the terms of any settlement agreement entered into between the Parties pursuant to California Code of Civil Procedure section 664.6. The Parties request that the Court retain such jurisdiction until full performance of

5. No Admission of Liability. This Stipulation and the dismissal contemplated herein shall not constitute, and shall not be construed or characterized as, an admission of liability, fault, wrongdoing, or the truth or falsity of any allegation by any Party. The Parties expressly disclaim any such admission. No Party shall characterize this Stipulation, the dismissal of this action, or the fact of settlement as a findi

6. Effectuation. The Parties respectfully request that the Clerk of the Court enter this dismissal forthwith upon execution of the accompanying Order. Each Party's counsel of record is authorized to execute this Stipulation on behalf of his or her respective client and hereby represents that he or she has been so authorized. A completed Request for Dismissal (Judicial Council Form CIV-110) is submitted concurrently w

7. Counterparts. This Stipulation may be executed in counterparts, each of which shall be deemed an original, and all of which together shall constitute one and the same instrument. Facsimile and electronically transmitted signatures shall be treated as original signatures for all purposes. Dated: January 26, 2024 WHITFIELD & ASSOCIATES By: ________ Cameron Whitfield (SBN 198745) 9465 Wilshire Boulevard, Suite 320 Be

1. The Complaint filed by Plaintiff Gavin Aldrich on December 9, 2022, and all causes of action asserted therein, including the first cause of action for Wrongful Termination in Violation of Public Policy, the second cause of action for Breach of Contract, the third cause of action for Breach of the Implied Covenant of Good Faith and Fair Dealing, the fourth cause of action for Declaratory Relief, and the fifth cause

2. The Amended Cross-Complaint filed by Defendant and Cross-Complainant Aurelius Media Americas Inc. on April 5, 2023, and all causes of action asserted therein, including the first cause of action for Breach of Employment Agreement, the second cause of action for Misappropriation of Trade Secrets under California Civil Code section 3426 et seq., the third cause of action for Breach of Fiduciary Duty, and the fourth

3. Each party shall bear its own costs and attorneys' fees incurred in connection with this action. No party is awarded costs or attorneys' fees against any other party.

4. Pursuant to the Parties' stipulation and California Code of Civil Procedure section 664.6, the Court retains jurisdiction over the Parties to enforce any settlement agreement entered into between the Parties in connection with the resolution of this action, until such time as full performance of the terms of said settlement agreement has been completed.

5. All pending hearing dates, deadlines, and trial dates in this action are hereby vacated. The Clerk is directed to close the file in this matter. Dated: ________ ________________________________________ Hon. Catherine Villanueva Judge of the Superior Court Department 52 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I, Marissa Tan, am employed in the County of Los Angeles, State of California. I am ove