FILED: NEW YORK COUNTY CLERK 04/14/2021 12:31 PM INDEX NO.

153554/2017
NYSCEF DOC. NO. 226 RECEIVED NYSCEF: 04/14/2021

Reference Files

COMPLAINANT'S
OLD STIPULATION
FILED: NEW ™"^ NO.
INDEX ™· 153554/2017
™°°''
NEW YORK COUNTY CLERK 04/14/2021 12:31 PM
'
[FILED: CLERK 01/17/2020 02:17 PM
NYSCEF
NYSCEF
DOC.
DOC..
NO. 226 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 04/14/2021
01/17/.

ile..

. www.MichaelTango.com.

e. www.NewYorkTango.org. (

f. www.LATanggBar.com.f

g. www.FostersNet.com. f
h. www.MetroCommuteSecurity.com.

i. www.ReunitedWebsom

J. www.Re-UnitedP/dLc

k. www.TekcTek.corri

1. www.TipsOnlumm .

m. www.NYRestel.com.

n. www.FamousNewYorker.com.

0. www.NYSuperTickets.com. /

p. www.TandBStudios.com. O

q. www.virtualtbs.com.

r. www.fosters.net.

s. Sef.. So
https://twitter.com/FostersNel fff q_.3

t. htt-ps://www.facebook.com/NewYorkTangp/. 7., -, G.

u. https://www.facebook.comlMichaelTango. AO

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 FILED: NEW NEW YORK
YORK COUNTY
COUNTY CLERK
CLERK 01/17/2020
04/14/202102:17
12:31PMJPM INDEX
'"^^
NO. 153554/2017
GLED:
NYSCEF DOC,
NYSCEF
DOC. NO.
NO. 161
226 RECEIVED
RECEIVED
NYSCEF:
NYSCEF: 04/14/2021
01/17 020

v. https://www.facebook.com/DanceWithMe.org.

w. https://www.instagram.com/tangomichael/.
§f
x. https://www.instagram.com/newvoritangpif

y. https://ving.co/u/1301587504348225536.
ff

z. https://www.youtübe.com/chaññ©l/UC EwOwM2a1705JGSoAw

5Al

aa.https://www.voutube.com/channel/UCVikwgixAQcGDNTzXTR9

7..
bb.https://www.youtube.com/user/BoomshakalalcalagaH.aff'ß

cc.https://www.voutube.com/channel/UCp3z6Ax60hEr9ZMZhl15.77)

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 FILED: NEW
NEW YORK
YORKCOUNTY
COUNTYCLERK
CLERK01 04/14/2021 12:31 PM INDEX NO. 153554/2017
LF1LED:
NYSCEF DOC.,
NYSCÍCF DOC.NO.
NO.161226 RECEIVED NYSCEF: 04/14/2021
01/17/2020
RECEIVED NYSCEF:

SUPREME COURT OF T vORK FOR USE OF CLERK:

COUNTY OF NEW
-- - --- - -------

CAROLINA GU

53554/2017

ON OF SETTLEMENT
MICHAEL 1

FOSTER, an ins

The Parties agree t ., i .f low:

1. Mr. Foster at t a or before February 3, 2020, will cause the /

permanent remova depüblishing and/or using down of any and all content over which
he has possession, custody or control whener directly or indirectly, concerning Mrs. Û
Carolina Gildred, her husband Mr. Ph Ep T. Giidred any member of the Mr. or Mrs.
Gildred's family, Mr. Gildred's professional, business or social organizations and
attorneys Seth Rafkin and Jennifer Bogue and Rafkin Esq., PLLC. This obligation,
includes, but is not limited to, causing the permanent removal epublishing and/or taking
down all of the sites, channels, profilm etc, 1sted in er 0.

2. Mr. F er rther a t he w ctly or indirectly, make any

further tement regarding Mrs. ildred r Mr. Gildred or any member of the Mr. or

Mrs. Gildred's amily . pro ssional, business or social organizations or

attorneys Seth fki B or Rafkin Esq., PLLC, that in any manner

disparages, defa es r eflec ñegati ly upon any of them. This obligation applies to
statements made i form of m la, including, but not limit 'd to, postings on or to y
internet site, YouTube, e hats T if MSO ed 4 An
f/46'
ulph w iEW'fS
3. Mr. Foster further agrees that he will not make any a mpt, di y or
indirectly, to contact in any manner, Mrs. Gildred or Mr. Gildred, any member of Mr. or d
Mrs. Gildred's family or Mr. Gildred's professional, business or social organizations. e

In the event Mr. Foster fails to comply with his obligations under this Stipulation of

Settlement, then, as permitted under New York Civil Practice Law and Rules 3215(i), Mrs.

And/or Mr. Gildred shall be ermitted to for entry of judgment in the amount of
/10O•
O 6( /h
against Mr. Foster. Pursuant to Rule

sci the Clerk of the Court shall enter ju ment without further notice against Mr.

'

dyeidPeM/k ø~AMS on g ke &«#d

cf &

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FILED: NEW
NEW YORK
YORK COUNTY
COUNTY CLERK
CLERK 04/14/2021 12:31 PM INDEX
'""^ NO.
™ 153554/2017
'
ILED: 01/17 / 2 02 0 02 : 17 PN|
NYSCEF
NYSCEF¯DOC., NO. 226
DOC. NO. 161 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 01/
04/14/2021
2020

Foster in said amount upon of: as to the

filing this Stipulation of Settlement, an affidavit
failure to comply with the terms statement
thereof, together with a complaint or a concise
of the facts on which the claim was based. Said interest
judgment shall include statutory
accruing from February 10, 2020. Mrs. or Mr. Gildred shall be permitted to seek an
also
order compelling Mr. Foster to with his obligations under this Stipulation of
comply
Settlement.

4. The Parties understand and agree that this Stipulation of Settlement shall
effect a dismissal of the action with prejudice all claims asserted against Mr.
including
Foster and all counterclaims by Mr. Foster.

5. This Stipulation of Settlement shall be governed by and construed in

accordance with the laws of the State of New York.

6. This Stipulation of Settlement constitutes the entire agreement between

the Parties, and supersedes any prior written or oral agreements, representations,
warranties or statements. This Stipulation of Settlement may not be modified, amended
or supplemented in any way except by a writing executed by the Parties hereto.

endant Michael Foster

January [7, 2020

Plainti ildred

January _L7 , 2020

Phili . Gildred

So okbee ch

HON. LOUIS L NOCK

J.S.C.

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