STIPULATED CONSENT DECREE AND PROPOSED ORDER

MARIA-ELENA JAMES, District Judge.

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 Animals, Inc. ("PETA") and Defendants, The Great Bull Run, LLC ("GBR") and Lone Star Rodeo, LLC ("Lone Star"), by and through their counsel of record, hereby stipulate that the claims in the present matter are settled in accordance with Fed. R. Civ. Pro. 54 and 58. Parties request that the court enter this Stipulated Consent Decree and Order as follows:

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 §§ 17200-10, related to events called "Great Bull Runs" in which bulls and humans ran on the same track, in a manner that Plaintiffs allege violated Cal. Penal Code §§ 597(b), 597b, and 597m;

Whereas, Defendant GBR conducted these events and Defendant Lone Star Rodeo supplied bulls for use in these events;

Whereas, the Parties now agree that it is in their best interests to resolve the action without litigation and have negotiated this Stipulated Consent Decree and Order in good faith to avoid expensive and protracted litigation;

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

Whereas, the Parties recognize, and the Court by entering this Stipulated Consent Decree and Order finds, that this Stipulated Consent Decree and Order has been negotiated by the parties in good faith and implementation of this Stipulated Consent Decree and Order will avoid expensive and protracted litigation, and that this Stipulated Consent Decree and Order is fair and reasonable.

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:

1. Defendant The Great Bull Run, LLC agrees to permanently refrain from conducting within the state of California the Great Bull Run or any other event in which bulls and humans run on the same track;

2. Defendant Lone Star Rodeo, LLC agrees to permanently refrain from supplying bulls for the purpose of using them within the state of California for the Great Bull Run or any other event in which bulls and humans run on the same track;

3. Each party shall bear its own costs and attorneys' fees in this action.

4. This Stipulated Consent Decree and Order constitutes the final, complete, and exclusive agreement and understanding among the Parties regarding the settlement embodied in the Stipulated Consent Decree and Order. The Parties acknowledge there are no representations, agreements, or understandings relating to the settlement other than those expressly contained in this Stipulated Consent Decree and Order.

5. The terms of this Stipulated Consent Decree are and shall be binding upon the present and future owners, officers, directors, employees, agents, representative, successors, and assigns of the Great Bull Run, LLC, and Lone Star Rodeo, LLC.

6. Upon entry of this Stipulated Consent Decree and Order by the Court, this Stipulated Consent Decree and Order shall constitute a final judgment between and among the Parties. The Court enters this judgment as a final judgment under Fed. R. Civ Proc. 54 and 58. The Court retains jurisdiction only as necessary to enforce the terms of the Stipulated Consent Decree and Order and the parties respectively expressly consent to the jurisdiction of this Court for the enforcement of this Stipulated Consent Decree and Order.

IT IS SO STIPULATED.