STIPULATION OF SETTLEMENT AND DISMISSAL WITH PREJUDICE

JOSEPH C. SPERO, District Judge.

IT IS HEREBY STIPULATED by and between the undersigned Plaintiffs and Defendants, by and through their respective attorneys, as follows:

1. Defendant United States Immigration and Customs Enforcement ("ICE") shall pay $42,156.98 (Forty two thousand one hundred fifty six dollars and ninety eight cents) to Plaintiffs in full and complete satisfaction of Plaintiffs' claims for attorneys' fees, costs, and litigation expenses under the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, as amended, in the above-captioned matter. This payment shall constitute full and final satisfaction of any and all of Plaintiffs' claims for attorneys' fees, costs, and litigation expenses in the above-captioned matter, and is inclusive of any interest. Payment of this money will be made by electronic funds transfer promptly after entry of this Stipulation onto the Court's docket and after receipt of necessary information from Plaintiffs in order to effectuate the payment. Defendant ICE will make all reasonable efforts to make payment within forty five (45) days of the date that Plaintiffs' counsel provides the necessary information for the electronic funds transfer and this Stipulation entered onto the Court's docket, whichever is later, but cannot guarantee payment within that time frame.

2. Upon the execution of this Stipulation, Plaintiffs, having received the records they requested, hereby release and forever discharge Defendants, their successors, the United States of America, and any department, agency, or establishment of the United States, and any officers, employees, agents, successors, or assigns of such department, agency, or establishment, from any and all claims and causes of action that Plaintiffs assert or could have asserted in this litigation, or which hereafter could be asserted by reason of, or with respect to, or in connection with, or which arise out of, the specific FOIA requests on which this action is based, including but not limited to all past, present, or future claims for attorneys' fees, costs, or litigation expenses in connection with the above-captioned litigation.

3. The provisions of California Civil Code Section 1542 are set forth below:

Plaintiffs having been apprised of the statutory language of Civil Code Section 1542 by Plaintiffs' attorney, and fully understanding the same, nevertheless elect to waive the benefits of any and all rights Plaintiffs may have pursuant to the provision of that statute and any similar provision of federal law. Plaintiffs understand that, if the facts concerning any injuries, liability for damages pertaining thereto, or liability for attorneys' fees, costs or litigation expenses are found hereafter to be other than or different than the facts now believed by it to be true, this Stipulation shall be and remain effective notwithstanding such material difference.

4. Execution of this Stipulation by counsel for the parties shall constitute a dismissal of all claims in this action with prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii).

5. The parties acknowledge that this Stipulation is entered into solely for the purpose of settling and compromising any remaining claims in this action without further litigation, and it shall not be construed as evidence or as an admission on the part of Defendants, the United States, its agents, servants, or employees regarding any issue of law or fact, or regarding the truth or validity of any allegation or claim raised in this action, or as evidence or as an admission by the Defendants regarding Plaintiffs' entitlement to attorneys' fees, costs, or other litigation expenses under FOIA. This Stipulation shall not be used in any manner to establish liability for fees or costs in any other case or proceeding involving Defendants.

6. This Stipulation is binding upon and inures to the benefit of the parties hereto and their respective successors and assigns.

7. If any provision of this Stipulation shall be held invalid, illegal, or unenforceable, the validity, legality, and enforceability of the remaining provisions shall not in any way be affected or impaired thereby.

8. This Stipulation shall constitute the entire agreement between the parties, and it is expressly understood and agreed that this Stipulation has been freely and voluntarily entered into by the parties hereto. The parties further acknowledge that no warranties or representations have been made on any subject other than as set forth in this Stipulation.

9. The persons signing this Stipulation warrant and represent that they possess full authority to bind the persons on whose behalf they are signing to the terms of the Stipulation.

10. This Stipulation may not be altered, modified or otherwise changed in any respect except in writing, duly executed by all of the parties or their authorized representatives.

11. It is contemplated that this Stipulation may be executed in several counterparts, with a separate signature page for each party. All such counterparts and signature pages, together, shall be deemed to be one document.

IT IS SO STIPULATED.

IT IS SO ORDERED.