-1- STIP. RE SETTL. AND REQ. FOR CONT. JURISDIC. PURSUANT TO CCP § 664.6; [PROPOSED] ORDER

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MITCHELL M. TSAI (Cal. Bar No. 277156) MITCHELL M. TSAI, ATTORNEY AT LAW 155 South El Molino Avenue, Suite 104 Pasadena, California 91101 Ph: (626) 381 – 9248 Fx: (626) 389 - 5414 Em: mitch@mitchtsailaw.com JAMES M. BIRKELUND (Cal. Bar No. 206328) GREENFIRE LAW, PC 2550 Ninth St. Suite 204B Berkeley, CA 94710 Ph: (415) 602-6223 Fx: (415) 789-4556 Em: jbirkelund@greenfirelaw.com Attorneys for Petitioners, CLIMATE RESOLVE, ENDANGERED HABITATS LEAGE, BRYAN BAKER, and CLYDE THOMAS WILLIAMS

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

CLIMATE RESOLVE, a California Nonprofit Corporation, BRYAN BAKER, an individual; and CLYDE THOMAS WILLIAMS, an individual;

Plaintiffs and Petitioners. v. CALIFORNIA DEPARTMENT OF TRANSPORTATION, a Public Agency; and DOES 1–100. Defendants, Respondents and Real

Parties In Interest.

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CASE NO.: BS166680 STIPULATION RE SETTLEMENT AND REQUEST FOR CONTINUING JURISDICTION PURSUANT TO CCP § 664.6; [PROPOSED] ORDER California Environmental Quality Act (Cal. Pub Res. Code § 21000 et seq.)

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-2- STIP. RE SETTL. AND REQ. FOR CONT. JURISDIC. PURSUANT TO CCP § 664.6; [PROPOSED] ORDER

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Plaintiffs and Petitioners Climate Resolve, Bryan Baker, and Clyde Thomas Williams

(collectively “Petitioners”) and Defendant and Respondent California Department of Transportation

(“Caltrans” or collectively with Petitioners as the “Parties”) through their respective undersigned

attorneys of record in the above-captioned proceeding hereby stipulate to the following:

RECITALS

WHEREAS, on December 16, 2016, Petitioners filed this action against Respondent under the

California Environmental Quality Act (“CEQA”), challenging the approval of a freeway and

transportation project called the High Desert Corridor Project in Los Angeles and San Bernardino

Counties, California (SCH #2010091084) (“Project”);

WHEREAS,as of September 4, 2019 the Parties have entered into an enforceable settlement

agreemen (“Agreement”), a true and correct copy of which is attached as Exhibit 1;

WHEREAS, pursuant to the Agreement, the parties request that the court retain jurisdiction to

enforce the terms of the Agreement pursuant to Section 664.6 of the Cal. Code of Civil Procedure;

WHEREAS, pursuant to the Agreement, Petitioners has agreed to dismiss the above identified

matter with prejudice; and

NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED BY THE PARTIES

THAT:

1. The Court dismiss the entire action of all parties and all causes of action with

prejudice;and

2. The Court retain jurisdiction to enforce the terms of the Agreement pursuant to CCP §

664.6.

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-4- STIP. RE SETTL. AND REQ. FOR CONT. JURISDIC. PURSUANT TO CCP § 664.6; [PROPOSED] ORDER

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[PROPOSED] ORDER

1. The Joint Stipulation re Settlement and Request for Continuing Jurisdiction Pursuant to

CCP § 664.6 is GRANTED.

2. This entire action is dismissed of all parties and all causes of action with prejudice.

3. The Court will retain jurisdiction to enforce the terms of the Agreement, a true and

correct copy of which is attached as Exhibit 1, pursuant to CCP § 664.6.

IT IS SO ORDERED.

DATED: ______________________ __________________________________ THE HONORABLE MARY H. STROBEL Judge of the Superior Court

EXHIBIT 1

-1- PROOF OF SERVICE

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PROOF OF SERVICE

I, Leon Ramsey Jr., being duly sworn, deposes and says: I am a citizen of the United States and work in Los Angeles County, California. I am over the

age of eighteen years and am not a party to the within entitled action. My business address is: 155 South El Molino Avenue, Pasadena, California 91101. I served this list of persons with the following document(s) on September 11, 2018: STIPULATION RE SETTLEMENT AND REQUEST FOR CONTINUING JURISDICTION PURSUANT TO CCP § 664.6; [PROPOSED] ORDER The document(s) was served on: Mark Berkebile, Deputy Attorney CALIFORNIA DEPARTMENT OF TRANSPORTATION 100 South Main Street, Suite 1300 Los Angeles, CA 90012-3702 E: mark.berkebile@dot.ca.gov

__ by electronic service, via either electronic transmission or notification consistent with

California Code of Civil Procedure 1010.6.

I declare under penalty of perjury, according to the laws of the State of California, that the foregoing is true and correct.

Executed this September 12, 2019 at Pasadena, California.

_______________________ Leon Ramsey Jr.

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