UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -----------------------------------------------------------------------x BRADFORD CAMPEAU-LAURION,

Plaintiff,

-against-

RAYMOND KELLY, Commissioner of the New York City Police Department; THE CITY OF NEW YORK; THE NEW YORK YANKEES PARTNERSHIP; RICARDO BOCACHICA, an NYPD Detective; and DAVID ROBERTS, an NYPD Detective,

Defendants.

JUDGMENT PURSUANT TO RULE 68

09 CV 3790 (JSR)

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WHEREAS, plaintiff commenced this action by filing a complaint on April 15,

2009, alleging violations of his civil rights; and

WHEREAS, on June 4, 2009, defendant City of New York made an Offer of

Judgment in this matter pursuant to Rule 68 of the Federal Rules of Civil Procedure (Exhibit A

attached hereto); and

WHEREAS, on June 18, 2009, plaintiff accepted defendant City’s offer (Exhibit

B, attached hereto);

NOW, THEREFORE, IT IS HEREBY ORDERED THAT:

1. The City of New York shall pay plaintiff Bradford Campeau-Laurion the

sum of Ten Thousand and One Dollars ($10,001), pursuant to the Rule 68 offer of judgment.

The City of New York also shall pay plaintiff’s attorneys’ fees and costs in the amount of

Twelve Thousand Dollars ($12,000), as agreed by the parties to be reasonable attorneys’ fees and

costs as provided in the Rule 68 offer. The amount of the attorneys’ fees and costs shall be paid

to plaintiff’s attorneys, the New York Civil Liberties Union Foundation.

2. This judgment shall be in full satisfaction of all federal and state claims or

rights that plaintiff Bradford Campeau-Laurion may have to damages, or any other form of relief,

arising out of the alleged acts or omissions of defendants City of New York, Raymond Kelly,

Ricardo Bocachica, and David Roberts, or any official or employee, either past or present, of the

City of New York, or any agency thereof including, but not limited to, the New York City Police

Department, in connection with the facts and circumstances that are the subject of this action.

3. The offer of judgment was made for the purposes specified in Rule 68 of the

Federal Rules of Civil Procedure, and is not to be construed as an admission of liability by

defendants City of New York, Raymond Kelly, Ricardo Bocachica, or David Roberts, or any

official, employee, representative, or agent of the City of New York, past or present, or the New

York City Police Department, or any other agency of the City of New York; nor is it an

admission that plaintiff Bradford Campeau-Laurion has suffered any damages.

4. Acceptance of the offer of judgment has acted to release and discharge

defendants City of New York, Raymond Kelly, Ricardo Bocachica, and David Roberts, their

successors and assigns, and all past and present officials, employees, representatives and agents

of the New York City Police Department, the City of New York, or any other agency thereof, or

the City of New York, from any and all claims that were or could have been alleged by plaintiff

Bradford Campeau-Laurion in this action. Acceptance of the offer of judgment has waived

plaintiff’s right to any claim for interest on the amount of the judgment. Plaintiff has agreed that

payment of $10,001 within 90 days of the date of acceptance of the offer shall be a reasonable

time for such payment.

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Dated: New York, New York _____________, 2009

SO ORDERED:

_______________________________________ JED S. RAKOFF, U.S.D.J.

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