Filing # 80153465 E-Filed 10/31/2018 03:53:56 PM. IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL DIVISION CASE NO. 18-007827 CC 26 PR NEWSWIRE ASSOCIATION LLC, vs. Plaintiff, MIDAM VENTURES LLC, a Florida limited liability company, Plaintiff, PR NEWSWIRE ASSOCIATION LLC, and Defendant, MIDAM VENTURES, LLC, a Florida limited liability company, in order to settle this case, agree: 4 2. 3. judgmentshall be entered against Defendant, that additional costs, interest, and attorney's Defendant. SETTLEMENT STIPULATION Defendant will pay Plaintiff $9,000.00, Defendant will pay the total as follows: Date Payment November 15, 2018 $1,750.00 December 15, 2018 1,750.00 January 15, 2019 1,750.00 February 15, 2019 4,750.00 March 15, 2019 2,000.00 Total: $9,000.00 If Defendant makes all payments in a timely fashion, Pleintiff agrees that noCASE NO, 18-007827 CC 26 fees, if any, shall be waived, and Plaintiff will fle @ Notice of Voluntary Dismissal With Prejudice with the court. 4. If Defendant shall default in payment hereunder, Plaintiff will be entitled to entry of a final judgment, without a hearing, for the principal amount of $13,784.00, plus court costs of $350.00, and prejudgment interest of $1,007.50, for a subtotal of $15,141.50, minus any payments made pursuant fo this Settlement Stipulation, plus postjudgment costs, alll attorney's fees, and additional prejudgment interest at the annual rate of 6.09% calculated from the date of default, after written application to the court, without notice or further hearing. 5. Defendant agrees that Plaintiffs rights under this Settlement Stipulation upon the Defendant's default, as described in paragraph 4, shail not be waived or fimited in any way by the Plaintiff's acceptance of payments by Defendant after default, Plaintiffs acceptance of such payments will merely reduce the total balance owed to Plaintif. 6. Defendant will make all payments payable to Markowitz, Ringel, Trusty & Hartog, P.A., Trust Account, and mail or deliver the payments to Thomas Ringel, Esq., Markowitz, Ringel, Trusty & Hartog, P.A., Two Datran Center, Suite 1800, 9130 South Dadeiand Boulevard, Miami, Florida 33156. 7. Plaintiff and Defendant for themselves, their heirs, executors, predecessors, subsidiaries, affiliates, officers, directors, partners, stockholders, agents, servants, employees, successors, assigns, trustees, and anyone claiming by or through them, or under their will, release and forever discharge each other and their heirs, executors, predecessors, subsidiaries, affiliates, officers, directors, partners, stockholders, agents, 2CASE NO. 18-007827 CC 28 servants, employees, successors, assigns, and counsel from any and all causes, rights, actions, suits, proceedings, debts, dues, contracts, damages, claims, and demands whatsoever in law or in equity, which they now have, which they had, or which they may at any time hereafter, by reason of any acts, causes, matters or things arising prior to the date this Settlement Stipulation is signed, which relate to the matters at issue in Plaintiff's Complaint and could have been asserted in this case. However, the provisions of this paragraph shall become null and void if Defendant fails to make any of the payments referred to in paragraph 2, or if Defendant files for protection under any chapter of the Bankruptcy Code, or an involuntary bankruptey is filed against Defendant prior to the time for filing the notice of voluntary dismissal with prejudice as set forth in paragraph 3. 8. The persons signing below on behalf of an entity represent that they are authorized and empowered to execute this Settlement Stipulation on behalf of the entity for which they are signing, and that the execution, delivery and performance of this Settlement Stipulation is duly authorized by the entity for which they are signing 9, Time is of the essence in this Settlement Stipulation. 10, A faxed copy of this Settlement Stipulation has the same evidentiary and legal effect as an original.