STIPULATED PERMANENT RESTRAINING ORDER

DALE S. FISCHER, District Judge.

FINDINGS

By stipulation of the parties and being advised of the premises, the Court finds:

WHEREAS, Plaintiff's counsel alleges and believes that over the past year Defendant Patrick J. Soria and his mother have engaged in numerous actions which constitute harassment as against Plaintiff Nationstar Mortgage LLC's counsel, Jered T. Ede, amongst others, which such alleged actions include, but are not limited to:

— Hijacking counsel's mother's mortgage;

— Researching counsel's entire California homeownership history, concluding with counsel's current personal residence, all without justification;

— Researched topics such as "how to f**k up an attorney" after this matter was filed;

— Conducted google.com searches on counsel and his wife; and

— Asked paid individuals to conduct surveillance on counsel (as well as this Court); among other things;

WHEREAS on Thursday, November 1, 2018, Defendant Soria requested Nationstar's counsel's consent to an order to release Defendant Soria from custody, which such consent was refused;

WHEREAS on Monday, November 5, 2018, counsel for Defendant Soria (without knowledge of the alleged harassing activities discussed herein) disclosed that Mr. Soria's mother, Soheila Soria, was putting pressure on Mr. Soria's counsel to file a motion seeking an order releasing Defendant Soria from custody and that there was a fear Ms. Soria might do "something stupid" to hurt herself;

WHEREAS Plaintiff's counsel, Jered T. Ede, Esq., represents that after dark on Tuesday, November 6, 2018 at approximately 8:30 p.m., two threatening men visited Mr. Ede's personal residence, one standing watch in his driveway while the other shouted at Mr. Ede and his family through the window that Mr. Ede should "cease and desist" or his "friend" would "take care of you tomorrow" and that Mr. Ede "knows what this is about;"

WHEREAS on Wednesday, November 7, 2018, Mr. Ede was then presented with a seven page letter from Mr. Soria's counsel (who has no knowledge of the November 6, 2018 events above) containing a list of reasons why Mr. Soria believed he should be released from custody;

WHEREAS on Thursday, November 8, 2018, Mr. Soria's counsel filed the aforementioned motion seeking to release Mr. Soria from federal custody; and

WHEREAS the parties agree and understand that this stipulation is part of a compromise of disputed claims and that the provisions contained herein are not intended to be — and shall not be — construed as an admission of any liability, responsibility, or wrongdoing whatsoever, and that each undersigned party expressly denies any liability, responsibility, or wrongdoing;

THEREFORE, sufficient grounds having been shown, the parties and Soheila Soria HEREBY STIPULATE AND AGREE to the entry of the following order:

RESTRAINING ORDER

NOW, THEREFORE, it is hereby ORDERED that:

Protected Persons, as used herein, shall mean and include Howard D. Hall, Jered T. Ede, Jane M. Kutepova, Timothy A. Burnett, Carina Gallardo, Cheyenne Schneider and each of their spouses/domestic partners (registered or not), children, relatives, employees, co-workers, and agents, whether herein named or not1, including but not limited to those individuals identified on Exhibit "A" — filed under seal in this matter. Exhibit "A" shall not be disclosed to the Restrained Persons at any time by anyone. Exhibit "A" may be amended from time to time upon application to this Court by any Protected Person(s).

Restrained Persons, as used herein, shall mean and include Patrick J. Soria2. The information on the herein named Restrained Persons is as follows:

IT IS SO ORDERED.

STIPULATED AND AGREED:

EXHIBIT "A"

FILED UNDER SEAL

EXHIBIT "A" — FILED UNDER SEAL

NOT TO BE DISCLOSED TO RESTRAINED PERSONS