Animal Legal Defense Fund et al v. The Great Bull Run, LLC et al

Filing 46

STIPULATED CONSENT DECREE AND ORDER; ***Civil Case Terminated. Signed by Judge Maria-Elena James on 3/10/2015. (cdnS, COURT STAFF) (Filed on 3/10/2015)

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Corey A. Evans (Cal. Bar No. 218789)
[e-mail]
Geneva Page (Cal. Bar No. 235633)
[e-mail]
EVANS & PAGE
2912 Diamond Street #346
San Francisco, CA 94131
Ph: [phone]
Fax: [phone]
Matthew Liebman (Cal. Bar No. 248861)
[e-mail]
ANIMAL LEGAL DEFENSE FUND
170 East Cotati Avenue
Cotati, CA 94931
Ph: [phone], ext. 1028
Fax: [phone]
Matthew Strugar (Cal. Bar No. 232951)
[e-mail]
PETA Foundation
2154 W. Sunset Blvd.
Los Angeles, CA 90026
Ph: [phone]
Fax: [phone]

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Jenni James (Cal. Bar No. 286460)
[e-mail]
PETA Foundation
1536 16th St. NW
Washington, DC 20036
Ph: [phone]
Fax: [phone]

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ANIMAL LEGAL DEFENSE FUND, a
nonprofit corporation; PEOPLE FOR
THE ETHICAL TREATMENT OF
ANIMALS, INC., a nonprofit
corporation;

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Case No. 3:14-cv-01171-MEJ
STIPULATED CONSENT DECREE
AND [PROPOSED] ORDER

Plaintiffs,
v.

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THE GREAT BULL RUN, LLC; LONE
STAR RODEO, LLC; DOES 1-10;
Defendants.

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STIPULATED CONSENT DECREE AND PROPOSED ORDER
3:14-cv-01171-MEJ

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TO THIS HONORABLE COURT, ALL PARTIES HEREIN, AND THEIR
RESPECTIVE ATTORNEYS OF RECORD:
Plaintiffs Animal Legal Defense Fund (“ALDF”) and People for the Ethical Treatment of

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Animals, Inc. (“PETA”) and Defendants, The Great Bull Run, LLC (“GBR”) and Lone Star

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Rodeo, LLC (“Lone Star”), by and through their counsel of record, hereby stipulate that the claims

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in the present matter are settled in accordance with Fed. R. Civ. Pro. 54 and 58. Parties request that

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the court enter this Stipulated Consent Decree and Order as follows:

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Whereas, Plaintiffs filed a complaint against Defendants, alleging causes of action for
unfair competition under California’s Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code

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§§ 17200-10, related to events called “Great Bull Runs” in which bulls and humans ran on the

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same track, in a manner that Plaintiffs allege violated Cal. Penal Code §§ 597(b), 597b, and 597m;

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Whereas, Defendant GBR conducted these events and Defendant Lone Star Rodeo supplied

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bulls for use in these events;
Whereas, the Parties now agree that it is in their best interests to resolve the action without

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litigation and have negotiated this Stipulated Consent Decree and Order in good faith to avoid

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expensive and protracted litigation;

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Whereas, the Defendants deny the allegations of the complaint and do not admit any
liability arising out of the occurrences alleged in the complaint;

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Whereas, the Parties recognize, and the Court by entering this Stipulated Consent Decree

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and Order finds, that this Stipulated Consent Decree and Order has been negotiated by the parties

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in good faith and implementation of this Stipulated Consent Decree and Order will avoid

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expensive and protracted litigation, and that this Stipulated Consent Decree and Order is fair and

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reasonable.

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Now, therefore, without adjudication or admission of any issue of fact or law, the Parties,
by and through the undersigned, agree and stipulate as follows:

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STIPULATED CONSENT DECREE AND PROPOSED ORDER
3:14-cv-01171-MEJ

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March 10

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Agreed:

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DATED: _ __ __ __ , 2015

By:

Brad f'o~~ rd~S=c-u d~ er -~b e~h a~lf of
~ d--o n ~ - ~

Defen

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THE GREAT BULL RUN, LLC

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DATED:;a -

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,2015

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DATED: _ __ __ __ ,20
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By:

Matth------.,.~ eb m -o n 'e h a..
;-;- ew L i--;'-an --b '- lf,----of

Plaintiff ANIMAL LEGAL DEFENSE FUND

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,If

DATED: _ _ _ _ __ -',2015

By:

Jeff = K~e IT-o-n~b e h a~lf~o~f~--~~-

Plaintiff PEOPLE FOR TIIE ETHICAL
TREATMENT OF ANIMALS

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IT IS SO ORDERED.

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DATED: _ _ __ __ -', 2015

By: _ _ __ _ __ __
Honorable Maria-Elena James

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STIPULATED CONSENT DECREE AND P OPOSED ORDER
3:14-cv-OI171 -MEJ
\

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Agreed:

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DATED:

,2015

By:
Bradford Scudder on behalf of
Defendant THE GREAT BULL RUN, LLC

DATED:

,2015

By:
Preston Fowlkes, Jr. on behalf of
Defendant LONE STAR RODEO, LLC

,2015

By:
.,
Matthew Liebman on behalf of
DEFENSE FUND
Plaintiff

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DATED:

/4 .. t,

DATED:

f/;I~q!

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~~-.

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,2015
FOR THE ETHICAL
TREATMENT OF ANIMALS

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IT IS SO ORDERED.

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DATED:

,2015

By:
Honorable Maria-Elena James

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STIPULATED CONSENT DECREE AND PROPOSED ORDER
3:14-cv-0l171-MEJ

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