AGREED MOTION FOR DISMISSAL OF CASE AND ENTRY OF CONSENT JUDGMENT AND PERMANENT INJUNCTION

Jury Trial Demanded

JOHN ROBERT BLAKEY, District Judge.

Comes now Plaintiffs Linda Winkowski and Garrett See by and through Counsel and brings this Agreed Motion For Dismissal Of Case And Entry Of Consent Judgment And Permanent Injunction and states as follows:

1. On May 10, 2019, Linda Winkowski ("Ms. Winkowski") and Garrett See ("Mr. See") (collectively "Plaintiffs") brought suit against Jesse Bradfield ("Jesse") and Tracey Bradfield ("Tracey" or "Jesse's Mom") (collectively "Defendants") alleging claims that Jesse had violated 18 U.S.C. §§ 1030 and 2701, by illegally and fraudulently taking control of Ms. Winkowski's Yahoo email accounts, converting and destroying property in those accounts, excluding Ms. Winkowski from those accounts, and maliciously and wantonly committing torts of intrusion and private nuisance against Ms. Winkowski and Mr. See.

2. Further, as stated in the Complaint, for a substantial period of time, Plaintiffs allege Jesse stalked Ms. Winkowski using the Internet, sending repeated and unwelcome text messages and email messages, making unwanted telephone calls, and repeatedly sending correspondence to Ms. Winkowski through the U.S. Mail.

3. The Complaint further alleged that Tracey, Jesse's mom, engaged in Civil Conspiracy to commit these acts by providing Jesse with the electronic devices he used to commit the acts, telephone access, Internet access, and by not cutting off Jesse's access to the Internet or those devices when she became aware of Jesse's bad conduct.

4. Plaintiffs and defendants agreed to compromise and settle this dispute to avoid the burden and expense of trial. The Parties have entered into a Confidential Settlement Agreement compromising and resolving this dispute.

5. Defendants have agreed in the Confidential Settlement Agreement to entry of the Consent Judgment and Permanent Injunction as well as dismissal of this matter (Ex. A, Consent Judgment). Further, Defendants have agreed to this Agreed Motion and have waived their appearance for the presentation and this Court's hearing of this Motion. (Ex. B, Waiver of Appearance.)

THEREFORE, for the reasons stated above, Plaintiffs ask this Court to enter the Consent Judgment and Permanent Injunction and dismiss this matter by agreement of the Parties.

Exhibit A

Consent Judgment And Permanent Injunction

The Parties, Plaintiffs Linda Winkowski and Garrett See, and Defendants, Jesse Bradfield and Tracey Bradfield, have settled this dispute. The Parties have entered into a Settlement Agreement, and the Parties have petitioned this Court for entry of an Order that would dismiss this matter and enter a Consent Judgment And Permanent Injunction. Defendants have Consented to Entry of a Consent Judgment And Permanent Injunction. Therefore, this Court Orders:

1. Jesse Bradfield is barred for life from any direct or indirect contact with Linda Winkowski and members of her family, in person or using any object, physical device, electronic device, electronic media, social media, the Internet, electronic mail, the U.S. Mail and/or any other form of communication written or electronic whether in existence or developed, whether visual, aural, tactile, or olfactory.

2. Jesse Bradfield is enjoined from using the Internet or any device or tool which is like the Internet or may replace or succeed the Internet, to conduct any searches for Linda Winkowski (her person or her name) or members of her family, to seek any information about Linda Winkowski (her person or her name) or about members of her family, to seek any image of Linda Winkowski (her person) or members of her family, or to use or to communicate Linda Winkowski's name, or the names of members of her family, in any way.

3. Jesse Bradfield is permitted to contact Ms. Winkowski's attorney for the purpose of giving effect to ongoing provisions of the Settlement Agreement among the Parties in this case.

4. Jesse and Tracey Bradfield shall provide to Plaintiffs' designated forensic expert access to their electronic devices, and Jesse Bradfield shall provide access to his Internet accounts according to the procedure agreed in the Confidential Settlement Agreement.

5. This Court will retain jurisdiction of this matter as required to enforce this Consent Judgment and Permanent Injunction and those other matters agreed by the Parties in their Settlement Agreement over which Seventh Circuit law permits this Court to retain jurisdiction.

6. This Order and the Consent Judgment and Permanent Injunction shall be reflected in the Final Judgment entered by the Court.

7. In all other respects, this matter is dismissed.

So Ordered.

Exhibit B

Waiver of Appearance

Comes now Jesse Bradfield ("Jesse") and Tracey Bradfield ("Tracey") (collectively "Defendants") and states as follows:

1. Defendants were served in this matter with a copy of the Summons and Complaint. Defendants have had the opportunity to review both documents. In addition. Plaintiffs had communicated with Defendants about the subject of the lawsuit before filing suit. and the Parties engaged in active discussion concerning settlement of this matter.

2. Defendants have signed and executed a confidential Settlement Agreement to resolve this dispute in full.

3. Defendants have agreed to entry of the Consent Judgment as part of the confidential Settlement Agreement. A copy of that Consent Judgment is attached to the Agreed Motion For Dismissal Of Case And Entry Of Consent Judgment And Permanent Injunction

3. Defendants have reviewed the Agreed Motion For Dismissal Of Case And Entry Of Consent Judgment And Permanent Injunction. ("Agreed Motion"). Defendants agreed to Plaintiffs' filing of the Agreed Motion, and to the Court's entry of the Agreed Motion and the Consent Judgment.

4. Defendants understand they could appear in court in this case and that they could appear in person for presentment and hearing of the Agreed Motion. Defendants waive their right to appear.