1 THE GORDON LAW GROUP DALE L. ALLEN, JR.—BAR NO. 145279 SAMUEL GORDON, ESQ. (SBN 305045) [email protected] 2 1885 The Alameda, Suite 210 KEVIN P. ALLEN—BAR NO. 252290 San Jose, CA 95126 [email protected] 3 Telephone: (408) 286-1351 ALLEN, GLAESSNER, HAZELWOOD & Fax: (408) 503-0954 WERTH, LLP 4 Email: [email protected] 180 Montgomery Street, Suite 1200 San Francisco, CA 94104 5 Attorney for Plaintiff JULIO AREVALO Telephone: (415) 697-2000 Facsimile: (415) 813-2045 6 JON A. HEABERLIN—BAR NO. 199810 [email protected] Attorneys for Defendants 7 RANKIN | STOCK | HEABERLIN | ONEAL SGT. DUJUAN E. GREEN and 96 No. Third Street, Suite 500 OFC. IAN JOHNSON 8 San Jose, California 95112-7709 Telephone: (408) 293-0463 TODD H. MASTER —BAR NO. 185881 9 Facsimile: (408) 293-9514 [email protected] HOWARD ROME MARTIN & RIDLEY 10 Attorney for Defendants CITY OF PALO LLP ALTO 1900 O’Farrell Street, Suite 280 11 (also sued as “PALO ALTO POLICE San Mateo, CA 94403 DEPARTMENT”), Telephone: (650) 365-7715 12 CHIEF ROBERT JONSEN, Facsimile: (650) 364-5297 LT. BEN BECCHETTI, LISA SCHEFF 13 Attorneys for Defendants MARK E. DAVIS—BAR NO. 79936 PALO ALTO POLICE SGT. JOHN 14 [email protected] ALANIZ ERIC J. BENGTSON—BAR NO. 254167 PALO ALTO POLICE OFFICER NICK 15 [email protected] ENBERG STEVEN B. DIPPELL—BAR NO. 121217 PALO ALTO POLICE OFFICER BRIAN 16 [email protected] CONNELLY DAVIS & YOUNG, APLC PALO ALTO POLICE OFFICER SASCHA 17 1960 The Alameda, Suite 210 PRIESS San Jose, CA 95126 (named herein as PALO ALTO POLICE 18 Telephone: (669) 245-4200 OFFICER PRIESS) Facsimile: (408) 985-1814 19 Attorneys for Defendant POLICE AGENT 20 THOMAS ALAN DESTEFANO, JR.

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3 UNITED STATES DISTRICT COURT

4 NORTHERN DISTRICT OF CALIFORNIA

5 SAN FRANCISCO DIVISION

6 Case No.: 3:20-CV-04157-CRB JULIO AREVALO, 7 STIPULATION AND (PROPOSED) ORDER Plaintiff, DISMISSING REMAINDER OF CASE 8 (INCLUDING DEFENDANT CITY OF PALO vs. ALTO) WITH PREJUDICE, RETENTION OF 9 JURISDICTION TO ENFORCE TERMS OF SETTLEMENT 10 CITY OF PALO ALTO, et al.,

11 Defendants,

12 IT IS HEREBY STIPULATED by and between the parties to this action1 through 13 their designated counsel that: 14 1. The Court, and specifically Mag. Judge Laurel Beeler, shall retain jurisdiction 15 pursuant to Kokkonen v. Guardian Life Ins. Co. of Am.,

(1994) to 16 enforce the terms of this settlement, which were memorialized on the record 17 before the Hon. Laurel Beeler on May 18, 2022, and which the main terms are 18 as follows: a) The City of Palo Alto shall pay to Plaintiff Julio Arevalo the total 19 sum of $150,000; b) Plaintiff shall release all Defendants and associated parties 20 which either were named or could have been named in this action; c) Plaintiff 21 and his counsel The Gordon Law Group shall bear any liens which may exist in 22 this matter, including but not limited to any liens for medical care or attorney’s 23 fees; and d) Defendants disputed liability in this matter and the payment of this 24 settlement should not be construed as an admission of liability. 25 26 27 1 The individual Defendants have been previously dismissed. Out of an abundance of caution and to effect the requirements of FRCP 41(a)(1)(A)(ii), all counsel are executing 1 2. Defendant CITY OF PALO ALTO (also sued as “City of Palo Alto Police 2 Department”), and all remaining Defendants (including DOE Defendants) shall 3 be dismissed with prejudice pursuant to FRCP 41(a)(1); and 4 3. The effectiveness of this Stipulation is conditioned on the District Court’s entry of 5 an Order retaining jurisdiction. 6 7 GORDON LAW GROUP /s/ Samuel J. Gordon 8 Samuel J. Gordon, Esq. Counsel for Plaintiff, Julio Arevalo 9 Dated: /s/ Aug. 22, 2022 HOWARD ROME MARTIN & RIDLEY 10 LLP RANKIN | STOCK | HEABERLIN, etc. /s/ Todd H. Master 11 /s/ Jon A. Heaberlin Todd H. Master, Esq. Jon A. Heaberlin, Esq. Counsel for (previously-dismissed) 12 Counsel for Defendants, City of Palo Alto, Defendants, Palo Alto Police Palo Alto Police Department, and Sgt. John Alaniz, Officer Nick Enberg, 13 (previously-dismissed) Defendants Chief Officer Brian Connelly, Officer Sascha 14 Jonsen, and Lt. Becchetti. Priess Dated: /s/ Aug. 1, 2022 Dated: /s/ Aug. 3, 2022 15 ALLEN, GLAESSNER, HAZELWOOD DAVIS & YOUNG, APLC 16 & WERTH, LLP /s/ Kevin P. Allen /s/ Steven B. Dippell 17 Kevin P. Allen, Esq. Steven B. Dippell, Esq. 18 Counsel for (previously-dismissed) Counsel for (previously-dismissed) Defendants, Sgt. Dujuan E. Defendant, Police Agent 19 Green and Officer Ian Johnson Thomas Alan DeStefano, Jr. Dated: /s/ Aug. 4, 2022 Dated: /s/ Aug. 1, 2022 20

21 ORDER 22 THE PARTIES HAVING STIPULATED, the Court orders the following: 23 1. This Court, and specifically Mag. Judge Laurel Beeler, shall retain jurisdiction 24 pursuant to Kokkonen v. Guardian Life Ins. Co. of Am.,

(1994) to 25 enforce the terms of this settlement, which were memorialized on the record 26 before the Hon. Laurel Beeler on May 18, 2022, and which the main terms are 27 as follows: a) The City of Palo Alto shall pay to Plaintiff Julio Arevalo the total 1 sum of $150,000; b) Plaintiff shall release all Defendants and associated parties 2 which either were named or could have been named in this action; c) Plaintiff 3 and his counsel The Gordon Law Group shall bear any liens which may exist in 4 this matter, including but not limited to any liens for medical care or attorney’s 5 fees; and d) Defendants disputed liability in this matter and the payment of this 6 settlement is not to be construed as an admission of liability. 7 2. Defendant CITY OF PALO ALTO (also sued as “City of Palo Alto Police 8 Department”), and all remaining Defendants (including DOE Defendants) shall 9 be dismissed with prejudice pursuant to FRCP 41(a)(1). 10 11 ||IT1IS SO ORDERED. 12 ||; DATED: November 21,2022 By: 13 JUDGE OF THE U.S. DISTRICT 44 COURT 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4- STIPIN ATION AND /DPODOGEDD OPNED NIQNICeINe PEMAINNER OF CAGE JINCIIIRNING REECENDANT OF □□□□ AITO WIT