Richard Orin Berge - Page 11

                                       - 10 -                                         
          No. 814944.  The settlement agreement states, in pertinent part,            
          as follows:                                                                 

                    Whereas, the parties hereto desire to resolve all                 
               matters between them without further litigation, together              
               with all claims, accounts, damages, demands and causes of              
               action which said parties ever had, now have, or may have in           
               the future arising from or in any way connected with the               
               matters asserted in the action herein, or which could have             
               been asserted in the action, including but not limited to a            
               claim or cause of action of any kind not arising from or               
               connected with the matters asserted in the action herein,              
               together with any and all representations made in connection           
               herewith by the parties;                                               
                    THEREFORE, in consideration of the following covenants,           
               obligations, and undertakings, it is hereby stipulated by              
               and between the parties as follows:                                    
                    1.  Judgment: Payment by Plaintiff [petitioner].                  
               Defendant [Ms. Wold] shall have judgment in her favor and              
               against plaintiff in the sum of Fifteen Thousand Dollars               
               ($15,000), plus interest at the legal rate from entry of               
               judgment, if any, in this action.  Defendant shall not have            
               the Judgement entered so long as plaintiff pays to Defendant           
               the following sum:                                                     
                         (a)  Six Thousand ($6,000) in Cash, Cashier’s                
               Check or Certified Funds on or before December 30, 2000;               
                         (b)  In no event shall the Six Thousand Dollars              
               ($6,000) be paid later than December 30, 2000, 5:00 p.m.               
               without such later payment being deemed a default on the               
               part of defendants, except by modification of this                     
               Stipulation in writing and executed by all parties hereto.             
                         *    *    *    *    *    *    *                              
                         (d)  Provided that the payment and Letter pursuant           
               to this Stipulation are received by defendant on or before             
               December 30, 2000, defendant will provide plaintiff with an            
               executed Request For Dismissal of her cross-complaint, with            
               prejudice upon payment timely made and plaintiff will                  
               provide defendant with an executed Request For Dismissal of            
               his complaint, with prejudice, and will execute a transfer             






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011