1033-00006 · Redstone Gaming Corp · Settlement Documents

stipulation-permanent-injunction.docx DOCUMENT Litigation

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

STIPULATION AND [PROPOSED] ORDER FOR ENTRY OF PERMANENT INJUNCTION

I. STIPULATION

A. Preamble

Plaintiff Redstone Gaming Corp. ("RGC"), a Nevada corporation, publicly traded on the Nasdaq Stock Market under the ticker symbol RDGM, with its principal offices located at 8800 Crimson Ridge Parkway, Suite 1200, Las Vegas, Nevada 89113, by and through its counsel of record, Calderwood & Harkness LLP (Francesca Morano, SBN 247891; Samuel Eklund, SBN 289734; Carlos Espinoza, SBN 301256; Hannah Brinkley, SBN 318492), 333 South Grand Avenue, Suite 4800, Los Angeles, California 90071, telephone (213) 555-7400, facsimile (213) 555-7401;

Defendant Grizzly Peak Research LLC ("GPR"), a Delaware limited liability company, with its principal office at 44 Maiden Lane, 7th Floor, San Francisco, California 94108, by and through its counsel of record, Caldwell, Tseng & Barrow LLP (Raymond Caldwell, SBN 195328; Natalie Orenstein, SBN 276541), 555 California Street, Suite 3100, San Francisco, California 94104, telephone (415) 555-2900, facsimile (415) 555-2901;

Defendant Grizzly Peak Capital Partners LP ("GPCP"), a Delaware limited partnership, with its principal office at 44 Maiden Lane, 7th Floor, San Francisco, California 94108, by and through its counsel of record, Caldwell, Tseng & Barrow LLP (Raymond Caldwell, SBN 195328; Natalie Orenstein, SBN 276541), 555 California Street, Suite 3100, San Francisco, California 94104;

Defendant Tobias Fenchurch ("Fenchurch"), an individual, who serves as the Managing Member of Grizzly Peak Research LLC and the sole managing member of Grizzly Peak Capital GP LLC (itself the sole general partner of Grizzly Peak Capital Partners LP), by and through his counsel of record, Caldwell, Tseng & Barrow LLP (Raymond Caldwell, SBN 195328; Natalie Orenstein, SBN 276541), 555 California Street, Suite 3100, San Francisco, California 94104;

(RGC, GPR, GPCP, and Fenchurch are referred to herein collectively as the "Parties" and individually as a "Party")

hereby stipulate and agree to the entry of the [Proposed] Order for Permanent Injunction set forth below, on the following terms and for the following reasons:

B. Recital of Background Facts

WHEREAS, this action was commenced by the filing of the Complaint on February 5, 2024, in the Superior Court of the State of California, County of Los Angeles, and assigned Case No. 24STCV-01892. On March 18, 2024, Plaintiff filed the operative First Amended Complaint, asserting the following causes of action: (1) Trade Libel pursuant to California Civil Code § 46(3); (2) Intentional Interference with Prospective Economic Advantage; (3) Unfair Business Practices pursuant to California Business & Professions Code § 17200 et seq.; and (4) Negligent Misrepresentation;

WHEREAS, the claims asserted in this action arise from the research, authorship, publication, and dissemination by Defendant Grizzly Peak Research LLC of three analytical reports concerning Plaintiff Redstone Gaming Corp. and its business operations, financial reporting, regulatory compliance, and corporate governance (collectively, the "Reports"), specifically:

(i) A report titled "House of Cards: Redstone Gaming's Manufactured Earnings," published on or about February 7, 2024, consisting of approximately forty-eight (48) pages (the "First Report");

(ii) A report titled "Rigged Reels: How Redstone's Slot Software Cheats the Regulators," published on or about February 14, 2024, consisting of approximately thirty-six (36) pages (the "Second Report"); and

(iii) A report titled "Double Down on Fraud: Redstone's Related-Party Shell Game," published on or about February 21, 2024, consisting of approximately twenty-nine (29) pages (the "Third Report");

WHEREAS, the Reports were published on the website grizzlypeakresearch.com and were further disseminated through the social media account @GrizzlyPeakRes on the platform commonly known as X (formerly Fenmore Solutions), which account had approximately 142,000 followers at the time of publication. The Reports were also made available to subscribers of GPR's electronic mailing list and were subsequently republished and referenced by various financial media outlets, investment forums, and social media aggregators;

WHEREAS, the Reports alleged, among other things: (a) that Redstone Gaming Corp. had fabricated approximately $410 million in fiscal year 2023 revenue through a network of fictitious intercompany transactions designed to inflate reported earnings; (b) that Redstone Gaming Corp. had manipulated its proprietary random-number-generator ("RNG") software to artificially inflate payout statistics reported to the Nevada Gaming Control Board, thereby deceiving both regulators and the investing public; and (c) that Marcus J. Calloway, the Chief Executive Officer of Redstone Gaming Corp., had engaged in undisclosed related-party dealings with a purported shell entity known as "Vermilion Holdings LLC," resulting in the diversion of corporate assets for personal benefit;

WHEREAS, all three categories of allegations set forth in the Reports were independently investigated and determined to be without factual basis:

(i) Pinnacle Audit & Advisory LLP, the independent registered public accounting firm retained by Redstone Gaming Corp., conducted a comprehensive re-examination of RGC's fiscal year 2023 revenue recognition practices and intercompany transactions and confirmed the accuracy of RGC's reported revenue figures in all material respects;

(ii) The Nevada Gaming Control Board completed an independent audit of Redstone Gaming Corp.'s random-number-generator software and related payout reporting on March 29, 2024, and issued findings clearing RGC of any wrongdoing, manipulation, or regulatory non-compliance;

(iii) An informal inquiry opened by the United States Securities and Exchange Commission in or about March 2024 concerning the allegations raised in the Reports was closed with no enforcement action, no charges, and no findings of wrongdoing on August 16, 2024;

WHEREAS, at the time of publication of the Reports, Defendants held a collective short position of approximately 680,000 shares of RDGM common stock, representing a notional value of approximately $62.66 million, calculated based upon the closing price of $92.14 per share on February 6, 2024, the last trading day before publication of the First Report;

WHEREAS, following the publication of the Reports, the per-share price of RDGM common stock declined from $92.14 (closing price on February 6, 2024) to $72.80 (closing price on February 21, 2024), representing a cumulative decline of $19.34 per share, or approximately 21.0%. Based upon approximately 73.8 million shares of RDGM common stock outstanding during the relevant period, the aggregate market-capitalization loss attributable to this decline was approximately $1.427 billion;

WHEREAS, the Parties participated in a two-day mediation on December 3–4, 2024, before the Honorable Gerald K. Matsuda (Ret.) at the Westside Mediation Center, located at 11601 Wilshire Boulevard, Suite 1200, Los Angeles, California 90025. At the conclusion of the mediation, the Parties reached a settlement-in-principle, the material terms of which were memorialized in a binding Mediator's Term Sheet signed by all Parties and their respective counsel of record on December 4, 2024;

WHEREAS, the Parties subsequently negotiated, finalized, and executed a comprehensive Settlement Agreement and Mutual Release (the "Settlement Agreement"), effective as of January 6, 2025 (the "Effective Date"), which provides, inter alia, for: (a) a total monetary payment of Fourteen Million Seven Hundred Fifty Thousand Dollars ($14,750,000.00) by Defendants to Plaintiff; (b) the publication by Defendants of corrective statements retracting the false allegations contained in the Reports; (c) mutual releases of claims; and (d) the injunctive relief set forth herein;

WHEREAS, the Settlement Agreement provides that the entry of the Stipulated Permanent Injunction described herein is a material component of the settlement of this action, and Defendants' consent to such injunctive relief constitutes a material inducement for Plaintiff's agreement to settle this action on the terms set forth in the Settlement Agreement;

C. Stipulation Terms

NOW, THEREFORE, the Parties hereby stipulate and agree as follows:

1. The Parties stipulate and agree that this Court may enter the [Proposed] Order for Permanent Injunction set forth in Section II below. The Parties represent that the terms of the [Proposed] Order have been negotiated at arm's length, are fair and reasonable, and are consistent with the Settlement Agreement.

2. Defendants consent to the entry of the [Proposed] Order for Permanent Injunction and hereby waive any and all objections to the form, substance, and entry thereof, including, without limitation, any objections based on the sufficiency of evidence, the propriety of injunctive relief, or the scope of the relief granted.

3. This Stipulation is entered into voluntarily by all Parties and constitutes a material component of the comprehensive settlement of this action. Each Party represents that it has had a full and fair opportunity to consult with counsel regarding the terms and implications of this Stipulation and the [Proposed] Order.

4. The Court shall retain jurisdiction over this action and the Parties for the purpose of enforcing this Stipulation, the [Proposed] Order for Permanent Injunction, and the Settlement Agreement, pursuant to California Code of Civil Procedure § 664.6. The Parties expressly consent to such continuing jurisdiction.

5. All references to the "Effective Date" throughout this Stipulation and the [Proposed] Order shall mean January 6, 2025, the effective date of the Settlement Agreement and Mutual Release.

6. This Stipulation may be executed in counterparts, each of which shall be deemed an original and all of which, taken together, shall constitute one and the same instrument. Signatures transmitted by electronic means, including PDF or Brightwater Software, shall be deemed original signatures for all purposes.

D. Signatures to the Stipulation

DATED: January __, 2025

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) 555-7400 Facsimile: (213) 555-7401

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) 555-2900 Facsimile: (415) 555-2901

Attorneys for Defendants GRIZZLY PEAK RESEARCH LLC, GRIZZLY PEAK CAPITAL PARTNERS LP, and TOBIAS FENCHURCH

Date: ________

II. [PROPOSED] ORDER FOR ENTRY OF PERMANENT INJUNCTION

The Court, having reviewed the Stipulation of the Parties filed herewith, the Settlement Agreement and Mutual Release dated January 6, 2025, the pleadings and papers on file in this action, and all other matters of which the Court may take judicial notice, and good cause appearing therefor, hereby ORDERS as follows:

A. Definitions

For purposes of this Order, the following terms shall have the meanings set forth below:

1. "Reports" means, collectively: (i) the report titled "House of Cards: Redstone Gaming's Manufactured Earnings," published on or about February 7, 2024; (ii) the report titled "Rigged Reels: How Redstone's Slot Software Cheats the Regulators," published on or about February 14, 2024; and (iii) the report titled "Double Down on Fraud: Redstone's Related-Party Shell Game," published on or about February 21, 2024, each as authored and published by Grizzly Peak Research LLC. The term "Reports" includes the full text, any excerpts, summaries, appendices, exhibits, data tables, charts, graphs, and any supplemental materials published in connection with the foregoing reports.

2. "Substantially Similar Statements" means any written, oral, electronic, or other communication, in any medium or format, that repeats, reiterates, paraphrases, summarizes, or conveys the substance of any of the false allegations contained in the Reports, including but not limited to:

(a) allegations that Redstone Gaming Corp. fabricated revenue through fictitious intercompany transactions or otherwise materially overstated its reported revenue for fiscal year 2023 or any other fiscal period;

(b) allegations that Redstone Gaming Corp. manipulated, tampered with, or otherwise altered its random-number-generator software for the purpose of inflating payout statistics or other performance metrics reported to the Nevada Gaming Control Board or any other gaming regulator; and

(c) allegations that Marcus J. Calloway, the Chief Executive Officer of Redstone Gaming Corp., engaged in undisclosed related-party dealings with Vermilion Holdings LLC or any other entity, or that Redstone Gaming Corp. failed to disclose material related-party transactions involving any of its officers, directors, or affiliates;

in each case, where such allegations are presented as statements of fact rather than as clearly identified expressions of opinion. For the avoidance of doubt, the term "Substantially Similar Statements" does not include: (x) fair and accurate reports of judicial proceedings in this action; (y) neutral references to the existence of this litigation without repetition of the underlying false allegations; or (z) statements made in response to lawful compulsory process.

3. "Defendants" means Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch, and each of their respective officers, directors, members, managers, partners, agents, employees, representatives, successors, assigns, and any person or entity acting in concert or participation with any of them who has actual notice of this Order, whether by personal service or otherwise.

4. "RDGM Securities" means any and all securities of Redstone Gaming Corp. (Nasdaq: RDGM), including but not limited to: common stock; preferred stock; warrants; options (whether exchange-traded or over-the-counter); convertible instruments of any kind; equity swaps; total return swaps; contracts for difference; and any other derivative instruments, synthetic instruments, or financial products the value of which is derived from, based upon, or related to the price, value, or performance of Redstone Gaming Corp.'s securities.

5. "Effective Date" means January 6, 2025, the effective date of the Settlement Agreement and Mutual Release executed by the Parties.

6. "Injunction Period" means, for purposes of the trading restrictions set forth in Section D of this Order, the five (5) year period commencing on the Effective Date and ending on January 6, 2030.

B. Injunction Against Republication (Permanent)

7. Defendants, and each of them, are hereby permanently enjoined and restrained from:

(a) Republishing, reposting, redistributing, retransmitting, or otherwise making available, in whole or in part, any of the Reports on grizzlypeakresearch.com, the @GrizzlyPeakRes social media account, or any other website, social media platform, blog, publication, message board, electronic mailing list, podcast, video channel, or medium of communication, whether currently existing or hereafter created;

(b) Publishing, disseminating, distributing, or otherwise communicating, in whole or in part, any Substantially Similar Statements concerning Redstone Gaming Corp., its subsidiaries, affiliates, officers, directors, employees, or any of them, through any medium of communication whatsoever; and

(c) Authorizing, directing, assisting, encouraging, inducing, facilitating, or conspiring with any third party to republish the Reports or to publish, disseminate, or distribute Substantially Similar Statements.

8. The injunction set forth in Paragraph 7 of this Order is permanent in duration and shall have no expiration date. It shall remain in full force and effect unless and until modified or vacated by further order of this Court upon motion and a showing of good cause.

9. Carve-outs. Nothing in this Order shall be construed to prohibit Defendants from:

(a) Publishing the Corrective Publication on grizzlypeakresearch.com and the corrective social media statement on the @GrizzlyPeakRes account, in each case in the form and within the timeframe required by the Settlement Agreement;

(b) Responding to lawful compulsory process, including subpoenas, court orders, or formal requests issued by a court of competent jurisdiction, a governmental agency, or a self-regulatory organization, provided that Defendants shall, to the extent permitted by law, provide Plaintiff with prompt written notice of any such compulsory process prior to compliance;

(c) Making truthful statements of fact in compliance with applicable federal and state securities laws, rules, and regulations, provided that such statements do not constitute Substantially Similar Statements as defined in Paragraph 2 of this Order; or

(d) Communicating with their own legal counsel regarding matters related to this action, the Settlement Agreement, or compliance with this Order.

C. Injunction Against Trading in RDGM Securities (5-Year Term)

10. Defendants, and each of them, are hereby permanently enjoined and restrained, for the duration of the Injunction Period (January 6, 2025, through and including January 6, 2030), from:

(a) Purchasing, selling, short selling, covering, or otherwise trading in (whether directly or indirectly) any RDGM Securities, regardless of the exchange, market, or venue on which such transaction occurs;

(b) Establishing, maintaining, increasing, decreasing, or otherwise benefiting from any short position, long position, hedged position, or derivative position in RDGM Securities;

(c) Directing, advising, instructing, or recommending that any third party trade in RDGM Securities on behalf of, for the benefit of, or at the direction of any Defendant; and

(d) Communicating material nonpublic information about Redstone Gaming Corp. to any person for the purpose of enabling, facilitating, or inducing such person to trade in RDGM Securities.

11. The trading restrictions set forth in Paragraph 10 of this Order apply to accounts and positions held by Defendants directly or indirectly, including but not limited to accounts held by, or positions maintained through, any entity controlled by, or under common control with, any Defendant. Without limiting the generality of the foregoing, the trading restrictions apply to any accounts or positions held by or through Grizzly Peak Capital GP LLC, any fund, account, or investment vehicle managed or advised by any Defendant, and any family member or household member of Tobias Fenchurch acting at his direction or for his benefit.

12. Inadvertent Transactions. If any Defendant becomes aware of any inadvertent transaction in RDGM Securities during the Injunction Period—including, by way of example, a transaction executed by an index fund, exchange-traded fund, or automated investment vehicle in which a Defendant has a passive investment—such Defendant shall promptly, and in any event within five (5) business days of becoming aware of such transaction, (a) provide written notice to counsel for Plaintiff, identifying the nature, date, and size of the transaction and the circumstances under which it occurred, and (b) take all commercially reasonable steps to unwind or reverse such transaction. A good-faith inadvertent transaction by a passively managed index fund or exchange-traded fund in which a Defendant holds a de minimis interest (less than 1% of the fund's total assets) shall not be deemed a violation of this Order, provided that the Defendant provides timely notice as required by this Paragraph.

13. Automatic Termination. Upon expiration of the Injunction Period on January 6, 2030, the trading restrictions set forth in Paragraphs 10 through 12 of this Order shall automatically terminate without further order of this Court, and Defendants shall thereafter be free to trade in RDGM Securities in accordance with applicable law.

D. Requirement to Remove Reports

14. Within five (5) business days of the Effective Date (i.e., by January 13, 2025), Defendants shall permanently remove and take down all copies of the Reports, including all text, images, charts, graphs, appendices, and supplemental materials, from grizzlypeakresearch.com, the @GrizzlyPeakRes social media account, and any other website, platform, account, or digital property under Defendants' control or direction.

15. In addition to the removal required by Paragraph 14, Defendants shall use commercially reasonable efforts to cause the removal of any cached, archived, mirrored, or republished copies of the Reports from third-party platforms and search engines, including, without limitation, by:

(a) Submitting content removal requests and/or de-indexing requests to Severin Industries, Ashgrove Industries, Cascade Health IT, and any other major search engines;

(b) Submitting takedown requests to the Internet Archive (archive.org) and any other web archiving services;

(c) Submitting content removal requests to any social media platforms, financial forums, or investment research aggregators on which the Reports appear and which are known to Defendants; and

(d) Cooperating with Plaintiff's reasonable requests for assistance in connection with any additional removal efforts undertaken by Plaintiff.

16. Defendants shall retain no copies of the Reports in any format (electronic, paper, or otherwise), except as may be strictly required to comply with applicable document-retention obligations imposed by law, regulation, or court order. Any copies retained solely for such purposes shall be maintained in a secure location, shall not be distributed, shared, or otherwise made available to any person other than Defendants' legal counsel, and shall be promptly destroyed upon expiration of the applicable retention obligation.

E. Compliance and Enforcement

17. The Court shall retain jurisdiction over this action and the Parties for the purpose of enforcing this Order and the Settlement Agreement and Mutual Release, pursuant to California Code of Civil Procedure § 664.6. The Parties expressly consent to such continuing jurisdiction.

18. Any violation of this Order may be punished as contempt of court, and the Court may impose such sanctions as it deems appropriate, including but not limited to monetary sanctions, coercive sanctions, and compensatory sanctions. Nothing in this Order limits Plaintiff's right to seek damages or other remedies available at law or in equity arising from any violation of this Order.

19. Plaintiff may seek enforcement of this Order by noticed motion in this action, filed in Department 14 of this Court. In the event of exigent circumstances, Plaintiff may seek enforcement on shortened notice pursuant to California Code of Civil Procedure § 1005(b) and the Court's Local Rules, or by ex parte application as permitted by law.

20. In any proceeding to enforce this Order, Defendants shall bear the burden of establishing compliance with the terms of this Order by a preponderance of the evidence. Defendants' failure to maintain adequate records of compliance shall give rise to a rebuttable presumption of non-compliance.

21. In any proceeding to enforce this Order, the prevailing party shall be entitled to recover its reasonable attorneys' fees and costs incurred in connection with such proceeding, as determined by the Court.

F. Modification

22. This Order may be modified only: (a) upon written stipulation of all Parties, filed with the Court and approved by the Court by further written order; or (b) upon motion by any Party, with notice to all other Parties, upon a showing of good cause, materially changed circumstances, or other grounds sufficient to warrant modification of an injunction under applicable law. Any such motion shall be filed in Department 14 of this Court and shall be subject to the briefing and hearing schedule established by the Court.

G. Binding Effect

23. This Order shall be binding upon Defendants, and each of them, and their respective officers, directors, members, managers, partners, agents, employees, representatives, successors, and assigns, and upon any person or entity acting in concert or participation with any of them who receives actual notice of this Order by personal service or otherwise. The obligations imposed by this Order shall run with any successor entity, whether by merger, acquisition, assignment, or other transfer of ownership or control.

24. Within ten (10) business days of entry of this Order, Defendants shall serve a copy of this Order, by personal service, electronic mail, or certified mail, on every officer, director, member, manager, partner, and employee of Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Grizzly Peak Capital GP LLC. Defendants shall promptly file a declaration of compliance with this Paragraph with the Court, identifying each person served, the method of service, and the date of service.

H. Relationship to Settlement Agreement

25. This Order is entered pursuant to and in connection with the Settlement Agreement and Mutual Release dated January 6, 2025, between the Parties. The Court has reviewed the Settlement Agreement and finds that the injunctive relief set forth herein is consistent with the terms of the Settlement Agreement, is supported by good cause, and is appropriate under the circumstances.

26. In the event of any conflict or inconsistency between the terms of this Order and the terms of the Settlement Agreement, the terms of this Order shall control and govern.

27. Entry of this Order does not constitute an adjudication on the merits of any claim or defense asserted in this action. This Order is entered by stipulation of the Parties as part of a comprehensive settlement, and no inference shall be drawn from the entry of this Order regarding the merits or lack of merits of any Party's claims or defenses.

I. No Admission of Liability

28. Entry of this Order by stipulation is not, and shall not be construed as, an admission by any Defendant of liability, wrongdoing, fault, or the truth or accuracy of any allegation set forth in the Complaint, the First Amended Complaint, or any other pleading, motion, brief, declaration, or paper filed in this action. Defendants have denied, and continue to deny, all allegations of liability, wrongdoing, and fault.

29. Defendants enter into this Stipulation and consent to the entry of this Order solely for the purpose of resolving this litigation and avoiding the burden, expense, uncertainty, and distraction of continued proceedings. Nothing in this Order shall be offered or received into evidence in any other proceeding as an admission of liability or wrongdoing by any Defendant, except in a proceeding to enforce this Order or the Settlement Agreement.

J. Effective Date of Order

30. This Order shall become effective immediately upon entry by the Court and shall be filed by the Clerk of the Court in the records of this action.

IT IS SO ORDERED.

Dated: ___

________________________________________

HON. PATRICIA YAMAMOTO Judge of the Superior Court County of Los Angeles

III. PROOF OF SERVICE

PROOF OF SERVICE

STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

I am employed in the County of Los Angeles, State of California. I am over the age of eighteen (18) years and am not a party to the within action. My business address is 333 South Grand Avenue, Suite 4800, Los Angeles, California 90071.

On January __, 2025, I served the foregoing document described as:

STIPULATION AND [PROPOSED] ORDER FOR ENTRY OF PERMANENT INJUNCTION

on the interested parties in this action by transmitting a true and correct copy via electronic service through the Court's approved electronic filing and service provider to the following persons at the electronic service addresses shown below:

Raymond Caldwell, Esq. Natalie Orenstein, Esq. CALDWELL, TSENG & BARROW LLP 555 California Street, Suite 3100 San Francisco, California 94104 Telephone: (415) 555-2900 Facsimile: (415) 555-2901

Email: rcaldwell@ctblaw.com; norenstein@ctblaw.com

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

Francesca Morano, Esq. Carlos Espinoza, Esq. CALDERWOOD & HARKNESS LLP 333 South Grand Avenue, Suite 4800 Los Angeles, California 90071 Telephone: (213) 555-7400 Facsimile: (213) 555-7401

Email: fmorano@calderwoodharkness.com; cespinoza@calderwoodharkness.com

Attorneys for Plaintiff Redstone Gaming Corp.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Executed on January __, 2025, at Los Angeles, California.

________________________________________

[Name of Declarant]

Case No. 24STCV-01892

REDSTONE GAMING CORP., a Nevada corporation,	Case No. 24STCV-01892
Plaintiff,	Assigned for All Purposes to:

Hon. Patricia Yamamoto, Dept. 14

STIPULATION AND [PROPOSED] ORDER FOR ENTRY OF PERMANENT INJUNCTION

GRIZZLY PEAK RESEARCH LLC, a Delaware limited liability company; GRIZZLY PEAK CAPITAL PARTNERS LP, a Delaware limited partnership; and TOBIAS FENCHURCH, an individual,

Defendants.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
STIPULATION AND [PROPOSED] ORDER FOR ENTRY OF PERMANENT INJUNCTION
I. STIPULATION
A. Preamble
Plaintiff Redstone Gaming Corp. ("RGC"), a Nevada corporation, publicly traded on the Nasdaq Stock Market under the ticker symbol RDGM, with its principal offices located at 8800 Crimson Ridge Parkway, Suite 1200, Las Vegas, Nevada 89113, by and through its counsel of record, Calderwood & Harkness LLP (Francesca Morano, SBN 247891; Samuel Eklund, SBN 289734; Carlos Espinoza, SBN 301256; Hannah Brinkley, SBN 318492), 333 South Grand Avenue, Suite 4800, Los Angeles, California 90071, telephone (213) 555-7400, facsimile (213) 555-7401;
Defendant Grizzly Peak Research LLC ("GPR"), a Delaware limited liability company, with its principal office at 44 Maiden Lane, 7th Floor, San Francisco, California 94108, by and through its counsel of record, Caldwell, Tseng & Barrow LLP (Raymond Caldwell, SBN 195328; Natalie Orenstein, SBN 276541), 555 California Street, Suite 3100, San Francisco, California 94104, telephone (415) 555-2900, facsimile (415) 555-2901;
Defendant Grizzly Peak Capital Partners LP ("GPCP"), a Delaware limited partnership, with its principal office at 44 Maiden Lane, 7th Floor, San Francisco, California 94108, by and through its counsel of record, Caldwell, Tseng & Barrow LLP (Raymond Caldwell, SBN 195328; Natalie Orenstein, SBN 276541), 555 California Street, Suite 3100, San Francisco, California 94104;
Defendant Tobias Fenchurch ("Fenchurch"), an individual, who serves as the Managing Member of Grizzly Peak Research LLC and the sole managing member of Grizzly Peak Capital GP LLC (itself the sole general partner of Grizzly Peak Capital Partners LP), by and through his counsel of record, Caldwell, Tseng & Barrow LLP (Raymond Caldwell, SBN 195328; Natalie Orenstein, SBN 276541), 555 California Street, Suite 3100, San Francisco, California 94104;
(RGC, GPR, GPCP, and Fenchurch are referred to herein collectively as the "Parties" and individually as a "Party")
hereby stipulate and agree to the entry of the [Proposed] Order for Permanent Injunction set forth below, on the following terms and for the following reasons:
B. Recital of Background Facts
WHEREAS, this action was commenced by the filing of the Complaint on February 5, 2024, in the Superior Court of the State of California, County of Los Angeles, and assigned Case No. 24STCV-01892. On March 18, 2024, Plaintiff filed the operative First Amended Complaint, asserting the following causes of action: (1) Trade Libel pursuant to California Civil Code § 46(3); (2) Intentional Interference with Prospective Economic Advantage; (3) Unfair Business Practices pursuant to California Business & Professions Code § 17200 et seq.; and (4) Negligent Misrepresentation;
WHEREAS, the claims asserted in this action arise from the research, authorship, publication, and dissemination by Defendant Grizzly Peak Research LLC of three analytical reports concerning Plaintiff Redstone Gaming Corp. and its business operations, financial reporting, regulatory compliance, and corporate governance (collectively, the "Reports"), specifically:
(i) A report titled "House of Cards: Redstone Gaming's Manufactured Earnings," published on or about February 7, 2024, consisting of approximately forty-eight (48) pages (the "First Report");
(ii) A report titled "Rigged Reels: How Redstone's Slot Software Cheats the Regulators," published on or about February 14, 2024, consisting of approximately thirty-six (36) pages (the "Second Report"); and
(iii) A report titled "Double Down on Fraud: Redstone's Related-Party Shell Game," published on or about February 21, 2024, consisting of approximately twenty-nine (29) pages (the "Third Report");
WHEREAS, the Reports were published on the website grizzlypeakresearch.com and were further disseminated through the social media account @GrizzlyPeakRes on the platform commonly known as X (formerly Fenmore Solutions), which account had approximately 142,000 followers at the time of publication. The Reports were also made available to subscribers of GPR's electronic mailing list and were subsequently republished and referenced by various financial media outlets, investment forums, and social media aggregators;
WHEREAS, the Reports alleged, among other things: (a) that Redstone Gaming Corp. had fabricated approximately $410 million in fiscal year 2023 revenue through a network of fictitious intercompany transactions designed to inflate reported earnings; (b) that Redstone Gaming Corp. had manipulated its proprietary random-number-generator ("RNG") software to artificially inflate payout statistics reported to the Nevada Gaming Control Board, thereby deceiving both regulators and the investing public; and (c) that Marcus J. Calloway, the Chief Executive Officer of Redstone Gaming Corp., had engaged in undisclosed related-party dealings with a purported shell entity known as "Vermilion Holdings LLC," resulting in the diversion of corporate assets for personal benefit;
WHEREAS, all three categories of allegations set forth in the Reports were independently investigated and determined to be without factual basis:
(i) Pinnacle Audit & Advisory LLP, the independent registered public accounting firm retained by Redstone Gaming Corp., conducted a comprehensive re-examination of RGC's fiscal year 2023 revenue recognition practices and intercompany transactions and confirmed the accuracy of RGC's reported revenue figures in all material respects;
(ii) The Nevada Gaming Control Board completed an independent audit of Redstone Gaming Corp.'s random-number-generator software and related payout reporting on March 29, 2024, and issued findings clearing RGC of any wrongdoing, manipulation, or regulatory non-compliance;
(iii) An informal inquiry opened by the United States Securities and Exchange Commission in or about March 2024 concerning the allegations raised in the Reports was closed with no enforcement action, no charges, and no findings of wrongdoing on August 16, 2024;
WHEREAS, at the time of publication of the Reports, Defendants held a collective short position of approximately 680,000 shares of RDGM common stock, representing a notional value of approximately $62.66 million, calculated based upon the closing price of $92.14 per share on February 6, 2024, the last trading day before publication of the First Report;
WHEREAS, following the publication of the Reports, the per-share price of RDGM common stock declined from $92.14 (closing price on February 6, 2024) to $72.80 (closing price on February 21, 2024), representing a cumulative decline of $19.34 per share, or approximately 21.0%. Based upon approximately 73.8 million shares of RDGM common stock outstanding during the relevant period, the aggregate market-capitalization loss attributable to this decline was approximately $1.427 billion;
WHEREAS, the Parties participated in a two-day mediation on December 3–4, 2024, before the Honorable Gerald K. Matsuda (Ret.) at the Westside Mediation Center, located at 11601 Wilshire Boulevard, Suite 1200, Los Angeles, California 90025. At the conclusion of the mediation, the Parties reached a settlement-in-principle, the material terms of which were memorialized in a binding Mediator's Term Sheet signed by all Parties and their respective counsel of record on December 4, 2024;
WHEREAS, the Parties subsequently negotiated, finalized, and executed a comprehensive Settlement Agreement and Mutual Release (the "Settlement Agreement"), effective as of January 6, 2025 (the "Effective Date"), which provides, inter alia, for: (a) a total monetary payment of Fourteen Million Seven Hundred Fifty Thousand Dollars ($14,750,000.00) by Defendants to Plaintiff; (b) the publication by Defendants of corrective statements retracting the false allegations contained in the Reports; (c) mutual releases of claims; and (d) the injunctive relief set forth herein;
WHEREAS, the Settlement Agreement provides that the entry of the Stipulated Permanent Injunction described herein is a material component of the settlement of this action, and Defendants' consent to such injunctive relief constitutes a material inducement for Plaintiff's agreement to settle this action on the terms set forth in the Settlement Agreement;
C. Stipulation Terms
NOW, THEREFORE, the Parties hereby stipulate and agree as follows:
1.  The Parties stipulate and agree that this Court may enter the [Proposed] Order for Permanent Injunction set forth in Section II below. The Parties represent that the terms of the [Proposed] Order have been negotiated at arm's length, are fair and reasonable, and are consistent with the Settlement Agreement.
2.  Defendants consent to the entry of the [Proposed] Order for Permanent Injunction and hereby waive any and all objections to the form, substance, and entry thereof, including, without limitation, any objections based on the sufficiency of evidence, the propriety of injunctive relief, or the scope of the relief granted.
3.  This Stipulation is entered into voluntarily by all Parties and constitutes a material component of the comprehensive settlement of this action. Each Party represents that it has had a full and fair opportunity to consult with counsel regarding the terms and implications of this Stipulation and the [Proposed] Order.
4.  The Court shall retain jurisdiction over this action and the Parties for the purpose of enforcing this Stipulation, the [Proposed] Order for Permanent Injunction, and the Settlement Agreement, pursuant to California Code of Civil Procedure § 664.6. The Parties expressly consent to such continuing jurisdiction.
5.  All references to the "Effective Date" throughout this Stipulation and the [Proposed] Order shall mean January 6, 2025, the effective date of the Settlement Agreement and Mutual Release.
6.  This Stipulation may be executed in counterparts, each of which shall be deemed an original and all of which, taken together, shall constitute one and the same instrument. Signatures transmitted by electronic means, including PDF or Brightwater Software, shall be deemed original signatures for all purposes.
D. Signatures to the Stipulation
DATED: January __, 2025
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) 555-7400 Facsimile: (213) 555-7401
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) 555-2900 Facsimile: (415) 555-2901
Attorneys for Defendants GRIZZLY PEAK RESEARCH LLC, GRIZZLY PEAK CAPITAL PARTNERS LP, and TOBIAS FENCHURCH
Date: ________
II. [PROPOSED] ORDER FOR ENTRY OF PERMANENT INJUNCTION
The Court, having reviewed the Stipulation of the Parties filed herewith, the Settlement Agreement and Mutual Release dated January 6, 2025, the pleadings and papers on file in this action, and all other matters of which the Court may take judicial notice, and good cause appearing therefor, hereby ORDERS as follows:
A. Definitions
For purposes of this Order, the following terms shall have the meanings set forth below:
1.  "Reports" means, collectively: (i) the report titled "House of Cards: Redstone Gaming's Manufactured Earnings," published on or about February 7, 2024; (ii) the report titled "Rigged Reels: How Redstone's Slot Software Cheats the Regulators," published on or about February 14, 2024; and (iii) the report titled "Double Down on Fraud: Redstone's Related-Party Shell Game," published on or about February 21, 2024, each as authored and published by Grizzly Peak Research LLC. The term "Reports" includes the full text, any excerpts, summaries, appendices, exhibits, data tables, charts, graphs, and any supplemental materials published in connection with the foregoing reports.
2.  "Substantially Similar Statements" means any written, oral, electronic, or other communication, in any medium or format, that repeats, reiterates, paraphrases, summarizes, or conveys the substance of any of the false allegations contained in the Reports, including but not limited to:
(a) allegations that Redstone Gaming Corp. fabricated revenue through fictitious intercompany transactions or otherwise materially overstated its reported revenue for fiscal year 2023 or any other fiscal period;
(b) allegations that Redstone Gaming Corp. manipulated, tampered with, or otherwise altered its random-number-generator software for the purpose of inflating payout statistics or other performance metrics reported to the Nevada Gaming Control Board or any other gaming regulator; and
(c) allegations that Marcus J. Calloway, the Chief Executive Officer of Redstone Gaming Corp., engaged in undisclosed related-party dealings with Vermilion Holdings LLC or any other entity, or that Redstone Gaming Corp. failed to disclose material related-party transactions involving any of its officers, directors, or affiliates;
in each case, where such allegations are presented as statements of fact rather than as clearly identified expressions of opinion. For the avoidance of doubt, the term "Substantially Similar Statements" does not include: (x) fair and accurate reports of judicial proceedings in this action; (y) neutral references to the existence of this litigation without repetition of the underlying false allegations; or (z) statements made in response to lawful compulsory process.
3.  "Defendants" means Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch, and each of their respective officers, directors, members, managers, partners, agents, employees, representatives, successors, assigns, and any person or entity acting in concert or participation with any of them who has actual notice of this Order, whether by personal service or otherwise.
4.  "RDGM Securities" means any and all securities of Redstone Gaming Corp. (Nasdaq: RDGM), including but not limited to: common stock; preferred stock; warrants; options (whether exchange-traded or over-the-counter); convertible instruments of any kind; equity swaps; total return swaps; contracts for difference; and any other derivative instruments, synthetic instruments, or financial products the value of which is derived from, based upon, or related to the price, value, or performance of Redstone Gaming Corp.'s securities.
5.  "Effective Date" means January 6, 2025, the effective date of the Settlement Agreement and Mutual Release executed by the Parties.
6.  "Injunction Period" means, for purposes of the trading restrictions set forth in Section D of this Order, the five (5) year period commencing on the Effective Date and ending on January 6, 2030.
B. Injunction Against Republication (Permanent)
7.  Defendants, and each of them, are hereby permanently enjoined and restrained from:
(a) Republishing, reposting, redistributing, retransmitting, or otherwise making available, in whole or in part, any of the Reports on grizzlypeakresearch.com, the @GrizzlyPeakRes social media account, or any other website, social media platform, blog, publication, message board, electronic mailing list, podcast, video channel, or medium of communication, whether currently existing or hereafter created;
(b) Publishing, disseminating, distributing, or otherwise communicating, in whole or in part, any Substantially Similar Statements concerning Redstone Gaming Corp., its subsidiaries, affiliates, officers, directors, employees, or any of them, through any medium of communication whatsoever; and
(c) Authorizing, directing, assisting, encouraging, inducing, facilitating, or conspiring with any third party to republish the Reports or to publish, disseminate, or distribute Substantially Similar Statements.
8.  The injunction set forth in Paragraph 7 of this Order is permanent in duration and shall have no expiration date. It shall remain in full force and effect unless and until modified or vacated by further order of this Court upon motion and a showing of good cause.
9.  Carve-outs. Nothing in this Order shall be construed to prohibit Defendants from:
(a) Publishing the Corrective Publication on grizzlypeakresearch.com and the corrective social media statement on the @GrizzlyPeakRes account, in each case in the form and within the timeframe required by the Settlement Agreement;
(b) Responding to lawful compulsory process, including subpoenas, court orders, or formal requests issued by a court of competent jurisdiction, a governmental agency, or a self-regulatory organization, provided that Defendants shall, to the extent permitted by law, provide Plaintiff with prompt written notice of any such compulsory process prior to compliance;
(c) Making truthful statements of fact in compliance with applicable federal and state securities laws, rules, and regulations, provided that such statements do not constitute Substantially Similar Statements as defined in Paragraph 2 of this Order; or
(d) Communicating with their own legal counsel regarding matters related to this action, the Settlement Agreement, or compliance with this Order.
C. Injunction Against Trading in RDGM Securities (5-Year Term)
10.  Defendants, and each of them, are hereby permanently enjoined and restrained, for the duration of the Injunction Period (January 6, 2025, through and including January 6, 2030), from:
(a) Purchasing, selling, short selling, covering, or otherwise trading in (whether directly or indirectly) any RDGM Securities, regardless of the exchange, market, or venue on which such transaction occurs;
(b) Establishing, maintaining, increasing, decreasing, or otherwise benefiting from any short position, long position, hedged position, or derivative position in RDGM Securities;
(c) Directing, advising, instructing, or recommending that any third party trade in RDGM Securities on behalf of, for the benefit of, or at the direction of any Defendant; and
(d) Communicating material nonpublic information about Redstone Gaming Corp. to any person for the purpose of enabling, facilitating, or inducing such person to trade in RDGM Securities.
11.  The trading restrictions set forth in Paragraph 10 of this Order apply to accounts and positions held by Defendants directly or indirectly, including but not limited to accounts held by, or positions maintained through, any entity controlled by, or under common control with, any Defendant. Without limiting the generality of the foregoing, the trading restrictions apply to any accounts or positions held by or through Grizzly Peak Capital GP LLC, any fund, account, or investment vehicle managed or advised by any Defendant, and any family member or household member of Tobias Fenchurch acting at his direction or for his benefit.
12.  Inadvertent Transactions. If any Defendant becomes aware of any inadvertent transaction in RDGM Securities during the Injunction Period—including, by way of example, a transaction executed by an index fund, exchange-traded fund, or automated investment vehicle in which a Defendant has a passive investment—such Defendant shall promptly, and in any event within five (5) business days of becoming aware of such transaction, (a) provide written notice to counsel for Plaintiff, identifying the nature, date, and size of the transaction and the circumstances under which it occurred, and (b) take all commercially reasonable steps to unwind or reverse such transaction. A good-faith inadvertent transaction by a passively managed index fund or exchange-traded fund in which a Defendant holds a de minimis interest (less than 1% of the fund's total assets) shall not be deemed a violation of this Order, provided that the Defendant provides timely notice as required by this Paragraph.
13.  Automatic Termination. Upon expiration of the Injunction Period on January 6, 2030, the trading restrictions set forth in Paragraphs 10 through 12 of this Order shall automatically terminate without further order of this Court, and Defendants shall thereafter be free to trade in RDGM Securities in accordance with applicable law.
D. Requirement to Remove Reports
14.  Within five (5) business days of the Effective Date (i.e., by January 13, 2025), Defendants shall permanently remove and take down all copies of the Reports, including all text, images, charts, graphs, appendices, and supplemental materials, from grizzlypeakresearch.com, the @GrizzlyPeakRes social media account, and any other website, platform, account, or digital property under Defendants' control or direction.
15.  In addition to the removal required by Paragraph 14, Defendants shall use commercially reasonable efforts to cause the removal of any cached, archived, mirrored, or republished copies of the Reports from third-party platforms and search engines, including, without limitation, by:
(a) Submitting content removal requests and/or de-indexing requests to Severin Industries, Ashgrove Industries, Cascade Health IT, and any other major search engines;
(b) Submitting takedown requests to the Internet Archive (archive.org) and any other web archiving services;
(c) Submitting content removal requests to any social media platforms, financial forums, or investment research aggregators on which the Reports appear and which are known to Defendants; and
(d) Cooperating with Plaintiff's reasonable requests for assistance in connection with any additional removal efforts undertaken by Plaintiff.
16.  Defendants shall retain no copies of the Reports in any format (electronic, paper, or otherwise), except as may be strictly required to comply with applicable document-retention obligations imposed by law, regulation, or court order. Any copies retained solely for such purposes shall be maintained in a secure location, shall not be distributed, shared, or otherwise made available to any person other than Defendants' legal counsel, and shall be promptly destroyed upon expiration of the applicable retention obligation.
E. Compliance and Enforcement
17.  The Court shall retain jurisdiction over this action and the Parties for the purpose of enforcing this Order and the Settlement Agreement and Mutual Release, pursuant to California Code of Civil Procedure § 664.6. The Parties expressly consent to such continuing jurisdiction.
18.  Any violation of this Order may be punished as contempt of court, and the Court may impose such sanctions as it deems appropriate, including but not limited to monetary sanctions, coercive sanctions, and compensatory sanctions. Nothing in this Order limits Plaintiff's right to seek damages or other remedies available at law or in equity arising from any violation of this Order.
19.  Plaintiff may seek enforcement of this Order by noticed motion in this action, filed in Department 14 of this Court. In the event of exigent circumstances, Plaintiff may seek enforcement on shortened notice pursuant to California Code of Civil Procedure § 1005(b) and the Court's Local Rules, or by ex parte application as permitted by law.
20.  In any proceeding to enforce this Order, Defendants shall bear the burden of establishing compliance with the terms of this Order by a preponderance of the evidence. Defendants' failure to maintain adequate records of compliance shall give rise to a rebuttable presumption of non-compliance.
21.  In any proceeding to enforce this Order, the prevailing party shall be entitled to recover its reasonable attorneys' fees and costs incurred in connection with such proceeding, as determined by the Court.
F. Modification
22.  This Order may be modified only: (a) upon written stipulation of all Parties, filed with the Court and approved by the Court by further written order; or (b) upon motion by any Party, with notice to all other Parties, upon a showing of good cause, materially changed circumstances, or other grounds sufficient to warrant modification of an injunction under applicable law. Any such motion shall be filed in Department 14 of this Court and shall be subject to the briefing and hearing schedule established by the Court.
G. Binding Effect
23.  This Order shall be binding upon Defendants, and each of them, and their respective officers, directors, members, managers, partners, agents, employees, representatives, successors, and assigns, and upon any person or entity acting in concert or participation with any of them who receives actual notice of this Order by personal service or otherwise. The obligations imposed by this Order shall run with any successor entity, whether by merger, acquisition, assignment, or other transfer of ownership or control.
24.  Within ten (10) business days of entry of this Order, Defendants shall serve a copy of this Order, by personal service, electronic mail, or certified mail, on every officer, director, member, manager, partner, and employee of Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Grizzly Peak Capital GP LLC. Defendants shall promptly file a declaration of compliance with this Paragraph with the Court, identifying each person served, the method of service, and the date of service.
H. Relationship to Settlement Agreement
25.  This Order is entered pursuant to and in connection with the Settlement Agreement and Mutual Release dated January 6, 2025, between the Parties. The Court has reviewed the Settlement Agreement and finds that the injunctive relief set forth herein is consistent with the terms of the Settlement Agreement, is supported by good cause, and is appropriate under the circumstances.
26.  In the event of any conflict or inconsistency between the terms of this Order and the terms of the Settlement Agreement, the terms of this Order shall control and govern.
27.  Entry of this Order does not constitute an adjudication on the merits of any claim or defense asserted in this action. This Order is entered by stipulation of the Parties as part of a comprehensive settlement, and no inference shall be drawn from the entry of this Order regarding the merits or lack of merits of any Party's claims or defenses.
I. No Admission of Liability
28.  Entry of this Order by stipulation is not, and shall not be construed as, an admission by any Defendant of liability, wrongdoing, fault, or the truth or accuracy of any allegation set forth in the Complaint, the First Amended Complaint, or any other pleading, motion, brief, declaration, or paper filed in this action. Defendants have denied, and continue to deny, all allegations of liability, wrongdoing, and fault.
29.  Defendants enter into this Stipulation and consent to the entry of this Order solely for the purpose of resolving this litigation and avoiding the burden, expense, uncertainty, and distraction of continued proceedings. Nothing in this Order shall be offered or received into evidence in any other proceeding as an admission of liability or wrongdoing by any Defendant, except in a proceeding to enforce this Order or the Settlement Agreement.
J. Effective Date of Order
30.  This Order shall become effective immediately upon entry by the Court and shall be filed by the Clerk of the Court in the records of this action.
IT IS SO ORDERED.
Dated: ___
________________________________________
HON. PATRICIA YAMAMOTO Judge of the Superior Court County of Los Angeles
III. PROOF OF SERVICE
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
I am employed in the County of Los Angeles, State of California. I am over the age of eighteen (18) years and am not a party to the within action. My business address is 333 South Grand Avenue, Suite 4800, Los Angeles, California 90071.
On January __, 2025, I served the foregoing document described as:
STIPULATION AND [PROPOSED] ORDER FOR ENTRY OF PERMANENT INJUNCTION
on the interested parties in this action by transmitting a true and correct copy via electronic service through the Court's approved electronic filing and service provider to the following persons at the electronic service addresses shown below:
Raymond Caldwell, Esq. Natalie Orenstein, Esq. CALDWELL, TSENG & BARROW LLP 555 California Street, Suite 3100 San Francisco, California 94104 Telephone: (415) 555-2900 Facsimile: (415) 555-2901
Email: rcaldwell@ctblaw.com; norenstein@ctblaw.com
Attorneys for Defendants Grizzly Peak Research LLC, Grizzly Peak Capital Partners LP, and Tobias Fenchurch
Francesca Morano, Esq. Carlos Espinoza, Esq. CALDERWOOD & HARKNESS LLP 333 South Grand Avenue, Suite 4800 Los Angeles, California 90071 Telephone: (213) 555-7400 Facsimile: (213) 555-7401
Email: fmorano@calderwoodharkness.com; cespinoza@calderwoodharkness.com
Attorneys for Plaintiff Redstone Gaming Corp.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed on January __, 2025, at Los Angeles, California.
________________________________________
[Name of Declarant]
Case No. 24STCV-01892
REDSTONE GAMING CORP., a Nevada corporation, | Case No. 24STCV-01892
Plaintiff, | Assigned for All Purposes to:
Hon. Patricia Yamamoto, Dept. 14
v.
STIPULATION AND [PROPOSED] ORDER FOR ENTRY OF PERMANENT INJUNCTION
GRIZZLY PEAK RESEARCH LLC, a Delaware limited liability company; GRIZZLY PEAK CAPITAL PARTNERS LP, a Delaware limited partnership; and TOBIAS FENCHURCH, an individual,
Defendants.

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

I. STIPULATION

FOR PLAINTIFF REDSTONE GAMING CORP.:

CALDERWOOD & HARKNESS LLP

CALDWELL, TSENG & BARROW LLP

IT IS SO ORDERED.

III. PROOF OF SERVICE

PROOF OF SERVICE

STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

Record

Parties

Dates

Amounts