1033-00006 · Redstone Gaming Corp · Settlement Documents

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EXHIBIT C

To Settlement Agreement and Mutual Release dated January 6, 2025

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

STIPULATION FOR DISMISSAL OF ENTIRE ACTION WITH PREJUDICE

Plaintiff Redstone Gaming Corp. ("Plaintiff" or "RGC"), a Nevada corporation, by and through its attorneys of record, Calderwood & Harkness LLP (Francesca Morano, Samuel Eklund, Carlos Espinoza, and Hannah Brinkley), 333 South Grand Avenue, Suite 4800, Los Angeles, California 90071; Defendant Grizzly Peak Research LLC ("GPR"), a Delaware limited liability company, by and through its attorneys of record, Caldwell, Tseng & Barrow LLP (Raymond Caldwell and Natalie Orenstein), 555 California Street, Suite 3100, San Francisco, California 94104; Defendant Grizzly Peak Capital Partners LP ("GPCP"), a Delaware limited partnership, by and through the same counsel, Caldwell, Tseng & Barrow LLP; and Defendant Tobias Fenchurch ("Fenchurch"), an individual, by and through the same counsel, Caldwell, Tseng & Barrow LLP (collectively, the "Parties"), hereby stipulate and agree as follows:

RECITALS. A. This action was commenced by the filing of a Complaint by Plaintiff Redstone Gaming Corp. on February 5, 2024, in the Superior Court of the State of California, County of Los Angeles, and was assigned Case No. 24STCV-01892. The Complaint asserted causes of action against Defendant Grizzly Peak Research LLC for (1) Trade Libel pursuant to California Civil Code Section 46(3); (2) Intentional Interference with Prospective Economic Advantage; and (3) Unfair Business Practices pursuant to California Business and Professions Code Section 17200 et seq.

B. On March 18, 2024, Plaintiff filed a First Amended Complaint (the "FAC"), which added Grizzly Peak Capital Partners LP and Tobias Fenchurch as named Defendants and asserted a fourth cause of action for Negligent Misrepresentation against all Defendants. The FAC remains the operative pleading in this action.

C. The Parties, through their respective counsel, participated in a mediation on December 3–4, 2024, before the Honorable Gerald K. Matsuda (Ret.) at the Westside Mediation Center, 11601 Wilshire Boulevard, Suite 1200, Los Angeles, California 90025. The mediation was conducted pursuant to a Mediation Agreement executed by all Parties and their counsel.

D. At the conclusion of the mediation session on December 4, 2024, the Parties reached a settlement-in-principle, the material terms of which were memorialized in a binding Mediator's Term Sheet executed by all Parties and their respective counsel on that same date.

E. Thereafter, the Parties negotiated, finalized, and executed a comprehensive Settlement Agreement and Mutual Release dated January 6, 2025 (the "Settlement Agreement"), which resolves all claims, counterclaims, cross-claims, disputes, and controversies between and among the Parties arising out of or related to this action and the subject matter thereof. The Settlement Agreement sets forth the complete terms and conditions of the Parties' settlement, including but not limited to payment obligations, corrective publication requirements, injunctive relief, non-disparagement covenants, and confidentiality provisions.

F. This Stipulation is made and filed pursuant to the express terms of the Settlement Agreement, including Section 9.2 thereof, which requires the Parties to execute and file a stipulation for dismissal of the entire action with prejudice within ten (10) business days of the Effective Date of the Settlement Agreement, with a request that the Court retain jurisdiction pursuant to California Code of Civil Procedure Section 664.6.

G. The Parties desire to effectuate the dismissal of this action in its entirety, with prejudice, while preserving the Court's jurisdiction to enforce the Settlement Agreement in the event of any breach or dispute arising thereunder.

STIPULATED TERMS. NOW, THEREFORE, based on the foregoing Recitals, which are incorporated herein by this reference, the Parties hereby stipulate and agree to the following:

1. Dismissal with Prejudice. The Parties hereby stipulate that the entire action, Case No. 24STCV-01892, Redstone Gaming Corp. v. Grizzly Peak Research LLC, et al., including all claims asserted in the First Amended Complaint filed on March 18, 2024, and all causes of action stated therein — specifically, the first cause of action for Trade Libel (Cal. Civ. Code § 46(3)), the second cause of action for Intentional Interference with Prospective Economic Advantage, the third cause of action for Unfair Business Practices (Cal. Bus. & Prof. Code § 17200 et seq.), and the fourth cause of action for Negligent Misrepresentation — be dismissed with prejudice as to all Parties, that is, as to Plaintiff Redstone Gaming Corp. against Defendants Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch. Such dismissal shall be on the merits and shall operate as a final adjudication precluding the re-filing or re-assertion of any claim or cause of action that was asserted or could have been asserted in this action based upon the facts and circumstances alleged in the Complaint or the First Amended Complaint.

2. Dismissal of All Cross-Claims, Counterclaims, and Affirmative Defenses. To the extent that any cross-claims, counterclaims, cross-complaints, or affirmative defenses have been asserted by any party in this action, all such cross-claims, counterclaims, cross-complaints, and affirmative defenses are likewise dismissed with prejudice as to all parties who have asserted them.

3. Retention of Jurisdiction Pursuant to California Code of Civil Procedure Section 664.6. Notwithstanding the dismissal ordered pursuant to Paragraphs 1 and 2 above, the Parties hereby stipulate and respectfully request that the Court retain jurisdiction over the Parties and the subject matter of this action for the sole and express purpose of enforcing the terms and conditions of the Settlement Agreement and Mutual Release dated January 6, 2025, pursuant to California Code of Civil Procedure Section 664.6. This stipulation for retained jurisdiction is made by all Parties and is intended to satisfy the requirements of Section 664.6, including the requirement that the parties to the settlement request the Court's retention of jurisdiction. The Court's retained jurisdiction shall continue until all obligations under the Settlement Agreement have been fully performed by all Parties, including but not limited to the following:

(a) The payment of settlement funds in the aggregate amount of Fourteen Million Seven Hundred Fifty Thousand Dollars ($14,750,000.00) into escrow at Great Basin Trust Company, N.A., in accordance with the payment schedule and terms set forth in Section 3 of the Settlement Agreement;

(b) Full and complete compliance with the Corrective Publication requirements set forth in Exhibit A to the Settlement Agreement, including the publication of corrective statements in the form, manner, timing, and media outlets specified therein;

(c) Full and complete compliance with the Social Media Corrective Statement requirements set forth in Exhibit B to the Settlement Agreement, including the posting and maintenance of corrective statements on all designated social media platforms for the periods specified therein;

(d) Full and complete compliance with the terms and conditions of the Stipulated Permanent Injunction set forth in Exhibit D to the Settlement Agreement, including all prohibitions on future conduct and affirmative obligations contained therein;

(e) Full and complete compliance with the non-disparagement provisions set forth in Section 7 of the Settlement Agreement by all Parties, their officers, directors, members, partners, managers, employees, agents, and representatives; and

(f) Full and complete compliance with the confidentiality provisions set forth in Section 8 of the Settlement Agreement, including all restrictions on the disclosure of the terms of the settlement and the Settlement Agreement, subject to the exceptions expressly set forth therein.

Upon the full and complete performance of all obligations under the Settlement Agreement by all Parties, any Party may file a notice with the Court stating that all obligations have been performed and requesting that the Court's retained jurisdiction be terminated.

4. Attorneys' Fees and Costs. Each Party shall bear its own attorneys' fees and costs incurred in connection with this action, including but not limited to all fees and costs incurred in connection with the prosecution, defense, mediation, settlement, and dismissal of this action. No Party shall seek or be entitled to recover any attorneys' fees, costs, or expenses from any other Party, whether by motion, noticed motion, memorandum of costs, or otherwise, except as may be expressly provided in the Settlement Agreement with respect to enforcement proceedings.

5. Filing Deadline. Pursuant to Section 9.2 of the Settlement Agreement, this Stipulation is to be filed with the Court within ten (10) business days of the Effective Date of the Settlement Agreement. The Effective Date of the Settlement Agreement is January 6, 2025. Accordingly, the target filing date for this Stipulation is no later than February 19, 2025.

6. Authority. Each person executing this Stipulation on behalf of a Party represents and warrants that he or she has been duly authorized to execute this Stipulation on behalf of the respective Party, and that this Stipulation is binding upon the Party on whose behalf it is executed. Counsel for Plaintiff represent that they have been authorized by Plaintiff Redstone Gaming Corp. to enter into this Stipulation on its behalf. Counsel for Defendants represent that they have been authorized by each of the Defendants — Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch — to enter into this Stipulation on their respective behalf.

[Signatures on Following Page]

SIGNATURES TO STIPULATION FOR DISMISSAL WITH PREJUDICE

Case No. 24STCV-01892

FOR PLAINTIFF REDSTONE GAMING CORP.:

CALDERWOOD & HARKNESS LLP

By: ________

Francesca Morano, Responsible Partner 333 South Grand Avenue, Suite 4800 Los Angeles, California 90071 Telephone: (213) 555-7200 Facsimile: (213) 555-7201

Attorneys for Plaintiff Redstone Gaming Corp.

Date: ________

FOR DEFENDANTS GRIZZLY PEAK RESEARCH LLC, GRIZZLY PEAK CAPITAL PARTNERS LP, AND TOBIAS FENCHURCH:

CALDWELL, TSENG & BARROW LLP

By: ________

Raymond Caldwell, Lead Partner 555 California Street, Suite 3100 San Francisco, California 94104 Telephone: (415) 555-3400 Facsimile: (415) 555-3401

Attorneys for Defendants Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch

Date: ________

[PROPOSED] ORDER FOR DISMISSAL OF ENTIRE ACTION WITH PREJUDICE

The Court, having reviewed the foregoing Stipulation for Dismissal of Entire Action with Prejudice executed by Plaintiff Redstone Gaming Corp. and Defendants Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch, through their respective counsel of record, and good cause appearing therefor, the Court finds that the Stipulation has been duly executed by all Parties and their counsel and that the Parties have entered into a Settlement Agreement and Mutual Release dated January 6, 2025, resolving all claims and disputes in this action.

IT IS HEREBY ORDERED as follows:

1. The entire action, Case No. 24STCV-01892, Redstone Gaming Corp. v. Grizzly Peak Research LLC, et al., is hereby dismissed with prejudice as to all Parties and as to all claims asserted therein, including all four causes of action set forth in the First Amended Complaint filed on March 18, 2024, namely: (1) Trade Libel (Cal. Civ. Code § 46(3)); (2) Intentional Interference with Prospective Economic Advantage; (3) Unfair Business Practices (Cal. Bus. & Prof. Code § 17200 et seq.); and (4) Negligent Misrepresentation.

2. All cross-claims, counterclaims, cross-complaints, and affirmative defenses, if any, that have been asserted by any party in this action are hereby dismissed with prejudice.

3. Pursuant to California Code of Civil Procedure Section 664.6, and upon the stipulation of all Parties, this Court hereby retains jurisdiction over the Parties and the subject matter of this action for the purpose of enforcing the terms and conditions of the Settlement Agreement and Mutual Release dated January 6, 2025, until all obligations thereunder have been fully performed by all Parties. Any Party may apply to this Court, on noticed motion or by order to show cause, for enforcement of the Settlement Agreement in the event of an alleged breach or failure to perform.

4. Each Party shall bear its own attorneys' fees and costs incurred in connection with this action.

This Order constitutes a final, appealable order disposing of all claims and all parties in this action, subject only to the Court's retained jurisdiction for enforcement purposes as set forth in Paragraph 3 above.

IT IS SO ORDERED.

Dated: ________

________________________________________

Hon. Patricia Yamamoto Judge of the Superior Court Superior Court of California, County of Los Angeles

EXHIBIT C TO SETTLEMENT AGREEMENT AND MUTUAL RELEASE

Case No. 24STCV-01892

Redstone Gaming Corp. v. Grizzly Peak Research LLC, et al.

Superior Court of the State of California, County of Los Angeles

REDSTONE GAMING CORP., a Nevada corporation,	Case No. 24STCV-01892
Plaintiff,	STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL OF ENTIRE ACTION WITH PREJUDICE

Assigned for All Purposes to:

GRIZZLY PEAK RESEARCH LLC, a Delaware limited liability company; GRIZZLY PEAK CAPITAL PARTNERS LP, a Delaware limited partnership; and TOBIAS FENCHURCH, an individual,	Hon. Patricia Yamamoto, Dept. 34
Defendants.	Filed by: Plaintiff Redstone Gaming Corp. and Defendants Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch

EXHIBIT C
To Settlement Agreement and Mutual Release dated January 6, 2025
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
STIPULATION FOR DISMISSAL OF ENTIRE ACTION WITH PREJUDICE
Plaintiff Redstone Gaming Corp. ("Plaintiff" or "RGC"), a Nevada corporation, by and through its attorneys of record, Calderwood & Harkness LLP (Francesca Morano, Samuel Eklund, Carlos Espinoza, and Hannah Brinkley), 333 South Grand Avenue, Suite 4800, Los Angeles, California 90071; Defendant Grizzly Peak Research LLC ("GPR"), a Delaware limited liability company, by and through its attorneys of record, Caldwell, Tseng & Barrow LLP (Raymond Caldwell and Natalie Orenstein), 555 California Street, Suite 3100, San Francisco, California 94104; Defendant Grizzly Peak Capital Partners LP ("GPCP"), a Delaware limited partnership, by and through the same counsel, Caldwell, Tseng & Barrow LLP; and Defendant Tobias Fenchurch ("Fenchurch"), an individual, by and through the same counsel, Caldwell, Tseng & Barrow LLP (collectively, the "Parties"), hereby stipulate and agree as follows:
RECITALS.  A. This action was commenced by the filing of a Complaint by Plaintiff Redstone Gaming Corp. on February 5, 2024, in the Superior Court of the State of California, County of Los Angeles, and was assigned Case No. 24STCV-01892. The Complaint asserted causes of action against Defendant Grizzly Peak Research LLC for (1) Trade Libel pursuant to California Civil Code Section 46(3); (2) Intentional Interference with Prospective Economic Advantage; and (3) Unfair Business Practices pursuant to California Business and Professions Code Section 17200 et seq.
B. On March 18, 2024, Plaintiff filed a First Amended Complaint (the "FAC"), which added Grizzly Peak Capital Partners LP and Tobias Fenchurch as named Defendants and asserted a fourth cause of action for Negligent Misrepresentation against all Defendants. The FAC remains the operative pleading in this action.
C. The Parties, through their respective counsel, participated in a mediation on December 3–4, 2024, before the Honorable Gerald K. Matsuda (Ret.) at the Westside Mediation Center, 11601 Wilshire Boulevard, Suite 1200, Los Angeles, California 90025. The mediation was conducted pursuant to a Mediation Agreement executed by all Parties and their counsel.
D. At the conclusion of the mediation session on December 4, 2024, the Parties reached a settlement-in-principle, the material terms of which were memorialized in a binding Mediator's Term Sheet executed by all Parties and their respective counsel on that same date.
E. Thereafter, the Parties negotiated, finalized, and executed a comprehensive Settlement Agreement and Mutual Release dated January 6, 2025 (the "Settlement Agreement"), which resolves all claims, counterclaims, cross-claims, disputes, and controversies between and among the Parties arising out of or related to this action and the subject matter thereof. The Settlement Agreement sets forth the complete terms and conditions of the Parties' settlement, including but not limited to payment obligations, corrective publication requirements, injunctive relief, non-disparagement covenants, and confidentiality provisions.
F. This Stipulation is made and filed pursuant to the express terms of the Settlement Agreement, including Section 9.2 thereof, which requires the Parties to execute and file a stipulation for dismissal of the entire action with prejudice within ten (10) business days of the Effective Date of the Settlement Agreement, with a request that the Court retain jurisdiction pursuant to California Code of Civil Procedure Section 664.6.
G. The Parties desire to effectuate the dismissal of this action in its entirety, with prejudice, while preserving the Court's jurisdiction to enforce the Settlement Agreement in the event of any breach or dispute arising thereunder.
STIPULATED TERMS.  NOW, THEREFORE, based on the foregoing Recitals, which are incorporated herein by this reference, the Parties hereby stipulate and agree to the following:
1. Dismissal with Prejudice. The Parties hereby stipulate that the entire action, Case No. 24STCV-01892, Redstone Gaming Corp. v. Grizzly Peak Research LLC, et al., including all claims asserted in the First Amended Complaint filed on March 18, 2024, and all causes of action stated therein — specifically, the first cause of action for Trade Libel (Cal. Civ. Code § 46(3)), the second cause of action for Intentional Interference with Prospective Economic Advantage, the third cause of action for Unfair Business Practices (Cal. Bus. & Prof. Code § 17200 et seq.), and the fourth cause of action for Negligent Misrepresentation — be dismissed with prejudice as to all Parties, that is, as to Plaintiff Redstone Gaming Corp. against Defendants Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch. Such dismissal shall be on the merits and shall operate as a final adjudication precluding the re-filing or re-assertion of any claim or cause of action that was asserted or could have been asserted in this action based upon the facts and circumstances alleged in the Complaint or the First Amended Complaint.
2. Dismissal of All Cross-Claims, Counterclaims, and Affirmative Defenses. To the extent that any cross-claims, counterclaims, cross-complaints, or affirmative defenses have been asserted by any party in this action, all such cross-claims, counterclaims, cross-complaints, and affirmative defenses are likewise dismissed with prejudice as to all parties who have asserted them.
3. Retention of Jurisdiction Pursuant to California Code of Civil Procedure Section 664.6. Notwithstanding the dismissal ordered pursuant to Paragraphs 1 and 2 above, the Parties hereby stipulate and respectfully request that the Court retain jurisdiction over the Parties and the subject matter of this action for the sole and express purpose of enforcing the terms and conditions of the Settlement Agreement and Mutual Release dated January 6, 2025, pursuant to California Code of Civil Procedure Section 664.6. This stipulation for retained jurisdiction is made by all Parties and is intended to satisfy the requirements of Section 664.6, including the requirement that the parties to the settlement request the Court's retention of jurisdiction. The Court's retained jurisdiction shall continue until all obligations under the Settlement Agreement have been fully performed by all Parties, including but not limited to the following:
(a) The payment of settlement funds in the aggregate amount of Fourteen Million Seven Hundred Fifty Thousand Dollars ($14,750,000.00) into escrow at Great Basin Trust Company, N.A., in accordance with the payment schedule and terms set forth in Section 3 of the Settlement Agreement;
(b) Full and complete compliance with the Corrective Publication requirements set forth in Exhibit A to the Settlement Agreement, including the publication of corrective statements in the form, manner, timing, and media outlets specified therein;
(c) Full and complete compliance with the Social Media Corrective Statement requirements set forth in Exhibit B to the Settlement Agreement, including the posting and maintenance of corrective statements on all designated social media platforms for the periods specified therein;
(d) Full and complete compliance with the terms and conditions of the Stipulated Permanent Injunction set forth in Exhibit D to the Settlement Agreement, including all prohibitions on future conduct and affirmative obligations contained therein;
(e) Full and complete compliance with the non-disparagement provisions set forth in Section 7 of the Settlement Agreement by all Parties, their officers, directors, members, partners, managers, employees, agents, and representatives; and
(f) Full and complete compliance with the confidentiality provisions set forth in Section 8 of the Settlement Agreement, including all restrictions on the disclosure of the terms of the settlement and the Settlement Agreement, subject to the exceptions expressly set forth therein.
Upon the full and complete performance of all obligations under the Settlement Agreement by all Parties, any Party may file a notice with the Court stating that all obligations have been performed and requesting that the Court's retained jurisdiction be terminated.
4. Attorneys' Fees and Costs. Each Party shall bear its own attorneys' fees and costs incurred in connection with this action, including but not limited to all fees and costs incurred in connection with the prosecution, defense, mediation, settlement, and dismissal of this action. No Party shall seek or be entitled to recover any attorneys' fees, costs, or expenses from any other Party, whether by motion, noticed motion, memorandum of costs, or otherwise, except as may be expressly provided in the Settlement Agreement with respect to enforcement proceedings.
5. Filing Deadline. Pursuant to Section 9.2 of the Settlement Agreement, this Stipulation is to be filed with the Court within ten (10) business days of the Effective Date of the Settlement Agreement. The Effective Date of the Settlement Agreement is January 6, 2025. Accordingly, the target filing date for this Stipulation is no later than February 19, 2025.
6. Authority. Each person executing this Stipulation on behalf of a Party represents and warrants that he or she has been duly authorized to execute this Stipulation on behalf of the respective Party, and that this Stipulation is binding upon the Party on whose behalf it is executed. Counsel for Plaintiff represent that they have been authorized by Plaintiff Redstone Gaming Corp. to enter into this Stipulation on its behalf. Counsel for Defendants represent that they have been authorized by each of the Defendants — Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch — to enter into this Stipulation on their respective behalf.
[Signatures on Following Page]
SIGNATURES TO STIPULATION FOR DISMISSAL WITH PREJUDICE
Case No. 24STCV-01892
FOR PLAINTIFF REDSTONE GAMING CORP.:
CALDERWOOD & HARKNESS LLP
By: ________
Francesca Morano, Responsible Partner 333 South Grand Avenue, Suite 4800 Los Angeles, California 90071 Telephone: (213) 555-7200 Facsimile: (213) 555-7201
Attorneys for Plaintiff Redstone Gaming Corp.
Date: ________
FOR DEFENDANTS GRIZZLY PEAK RESEARCH LLC, GRIZZLY PEAK CAPITAL PARTNERS LP, AND TOBIAS FENCHURCH:
CALDWELL, TSENG & BARROW LLP
By: ________
Raymond Caldwell, Lead Partner 555 California Street, Suite 3100 San Francisco, California 94104 Telephone: (415) 555-3400 Facsimile: (415) 555-3401
Attorneys for Defendants Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch
Date: ________
[PROPOSED] ORDER FOR DISMISSAL OF ENTIRE ACTION WITH PREJUDICE
The Court, having reviewed the foregoing Stipulation for Dismissal of Entire Action with Prejudice executed by Plaintiff Redstone Gaming Corp. and Defendants Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch, through their respective counsel of record, and good cause appearing therefor, the Court finds that the Stipulation has been duly executed by all Parties and their counsel and that the Parties have entered into a Settlement Agreement and Mutual Release dated January 6, 2025, resolving all claims and disputes in this action.
IT IS HEREBY ORDERED as follows:
1. The entire action, Case No. 24STCV-01892, Redstone Gaming Corp. v. Grizzly Peak Research LLC, et al., is hereby dismissed with prejudice as to all Parties and as to all claims asserted therein, including all four causes of action set forth in the First Amended Complaint filed on March 18, 2024, namely: (1) Trade Libel (Cal. Civ. Code § 46(3)); (2) Intentional Interference with Prospective Economic Advantage; (3) Unfair Business Practices (Cal. Bus. & Prof. Code § 17200 et seq.); and (4) Negligent Misrepresentation.
2. All cross-claims, counterclaims, cross-complaints, and affirmative defenses, if any, that have been asserted by any party in this action are hereby dismissed with prejudice.
3. Pursuant to California Code of Civil Procedure Section 664.6, and upon the stipulation of all Parties, this Court hereby retains jurisdiction over the Parties and the subject matter of this action for the purpose of enforcing the terms and conditions of the Settlement Agreement and Mutual Release dated January 6, 2025, until all obligations thereunder have been fully performed by all Parties. Any Party may apply to this Court, on noticed motion or by order to show cause, for enforcement of the Settlement Agreement in the event of an alleged breach or failure to perform.
4. Each Party shall bear its own attorneys' fees and costs incurred in connection with this action.
This Order constitutes a final, appealable order disposing of all claims and all parties in this action, subject only to the Court's retained jurisdiction for enforcement purposes as set forth in Paragraph 3 above.
IT IS SO ORDERED.
Dated: ________
________________________________________
Hon. Patricia Yamamoto Judge of the Superior Court Superior Court of California, County of Los Angeles
EXHIBIT C TO SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Case No. 24STCV-01892
Redstone Gaming Corp. v. Grizzly Peak Research LLC, et al.
Superior Court of the State of California, County of Los Angeles
REDSTONE GAMING CORP., a Nevada corporation, | Case No. 24STCV-01892
Plaintiff, | STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL OF ENTIRE ACTION WITH PREJUDICE
v.
Assigned for All Purposes to:
GRIZZLY PEAK RESEARCH LLC, a Delaware limited liability company; GRIZZLY PEAK CAPITAL PARTNERS LP, a Delaware limited partnership; and TOBIAS FENCHURCH, an individual, | Hon. Patricia Yamamoto, Dept. 34
Defendants. | Filed by: Plaintiff Redstone Gaming Corp. and Defendants Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch