[PROPOSED] STIPULATED PERMANENT INJUNCTION

EDWARD M. CHEN, District Judge.

INTRODUCTION

In accordance with the Court's Order Granting Plaintiffs' Motion for Voluntary Dismissal dated November 15, 2012 (See Docket 531), Plaintiffs and Defendants jointly submit this proposed Stipulated Permanent Injunction ("Injunction"). The parties have consented to the entry of this Stipulated Permanent Injunction to resolve all matters of dispute between them in the above-entitled actions. Pursuant to the Court's November 15, 2012 Order, this proposed Stipulated Permanent Injunction contains all of the terms of the agreed-upon permanent injunction for this case.

Permanent Injunction

Plaintiffs and up to (4) four persons acting in concert, shall be permitted to unfettered access without any ticket requirement the following areas in order to conduct their free speech activity (i.e., videotaping, displaying signs, leafletting, or otherwise protesting):

(1) A three (3)-foot wide walkway running alongside the perimeter wall of the animal compound. Defendants or Ringling Bros. may construct a fence to demark the three (3)-foot wide walkway on side of walkway opposite the perimeter wall of the animal compound of the Ringling Bros. Circus events, located on the North and East sides and West side to the frontage road entrance gate, at the Oracle Arena in Oakland, California, to create a corridor.

(2) The barricaded corridor leading to the animal compound, the area outside of but directly adjacent to the corridor, and the gap between the corridor and the animal compound entrance except that there shall be a ten-foot buffer zone surrounding the entrance of the compound. Plaintiffs may temporarily be moved from the gap to permit movement of equipment and animals.

(3) The upper west landing area, up to the point where the west ramp joins the landing.

(4) One specific spot located in the area adjacent to the entrance to the north tunnel, which has a clear view of the entire tunnel. Here, only one person rather than four shall be permitted access.

(5) The north ramp and landing.

(6) The northeast stairs and base of the stairs.

Furthermore, Plaintiffs and persons acting in concert with them should be permitted free access to all exterior areas of the Arena and parking lot which are otherwise open to the public.

Defendants are required to distribute copies of the preliminary injunction to any security manager, security guard, and/or police officer providing security at the Arena during the circus engagement. Moreover, all security personnel should be briefed as to the material terms of the injunction.

In addition, Defendants shall designate one "point person" during the entirety of the circus engagement at the Arena, who shall be responsible for communicating with Mr. Cuviello and Ms. Bolbol in the event of a dispute and who has the power to make immediate decisions in regard thereto.

The preliminary injunction need only apply to circus events scheduled at the Coliseum/Arena, such as the Ringling Brothers Circus.

The Court shall retain jurisdiction over any disputes that arise with respect to these cases and the permanent injunction is hereby entered.

SO STIPULATED.

Therefore, Plaintiffs' motion for voluntary dismissal of is hereby GRANTED. Upon the filing of this document, the Clerk of the Court shall enter a final judgment and close the file in this case.

IT IS SO ORDERED.