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Davis Wricht TREMAINE LLP
865 S, FIGUEROA ST.
SUITE 2400 CONFORMED COPY
Los ANGELES, CALIFORNIA 90017-2566 aN A LT eaitomia
‘TELEPHONE (213) 633-6800 “Bounty 0
FAX (213) 633-6800 county of tos Anaetes
016
ALONZO WICKERS IV (State Bar No. 169454) JN 282
alonzowickers@dwt.com Sherri rxeguitve Ulfice/Clerk
KAREN A. HENRY (State Bar No. 229707) Deputy
com hambers
KATHLEEN CULLINAN (State Bar No. 287604) "shave Chamba
kathleencullinan@dwt.comn
Attomeys for Defendant
ELECTRONIC ARTS, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
JAMES BROWN, ) Case No, BC520019
) Assigned to the Hon. Maureen Dufiy-Lewis
Plaintiff,
vs. NOTICE OF PLAINTIFF'S ACCEPTANCE
} OF CCP § 998 OFFER
ELECTRONIC ARTS, INC, )
Defendant, Action Filed: August 30, 2013
)
)
2
a
NOTICE OF ACCEPTANCE OF OFFER TO COMPROMISE.
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TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that, on May 20, 2016, plaintiff James Brown accepted the Offer
to Compromise Pursuant to C.C.P. § 998 made by defendants Electronic Arts Inc. (“EA”).
Attached to this Notice as Exhibit A is a true and correct copy of the executed 998 offer.
DATED: June 28, 2016 Davis WRIGHT TREMAINE LLP
ALONZO WICKERS IV
KAREN A. HENRY
KATHLEEN CULLINAN
By: G.
Karen A. Henry
Attorneys for Defendant
ELECTRONIC ARTS, INC.
1 Davis Waiciy TREMAINE LLP
NOTICE OF ACCEPTANCE OF OFFER TO COMPROMISE. tos anes eatin les
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April 22, 2016
VIA FIRST CLASS U.S, MAIL
Elaine T. Byszewski
‘Hagens Berman Sobol Shapiro LLP
301 North Lake Avene
Pasadena, California 91101
Re: OFFER TO COMPROMISE PURSUANT TO C.C.P.§ 998
Brown y. Electronic Arts Inc.
‘LASC Case No, BCS20019
‘Dear Ms, Byszewski:
Pursuant to California Code of Civil Procedure Section 998, deftndant Electronic Arts
Inc. (“EA”) hereby offers to pay to plaintiff James Brown (“Plaintiff”) the sum of $600,000.00 to
‘compromise and settle the claims in this action, on the condition that Plaintiff agrees: (1) to
‘execute and file a request for dismissal of the entire action with prejudice; and (2) to execute a
settlement agreement and full and final release of all claims arising out of or relating to this
‘action. Each side shall bear its own costs and attorneys’ fees in connection with this
action, While Plaintiff and his couasel ultimately will decide how to allocate the offer between
‘them, BA believes that an approptiate allocation of this offer would be no more than $75,000 to
Plaintiff and the remainder in attorneys’ fees. .
‘This offer is made for the purposes specified in Section 998, and is not to be construed
cither as an admission that EA is liable in this action, or that Plaintiff has suffered any damage.
This offer will be withdrawn by operation of law if itis not accepted within the statutory period.
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aonBlaine T. Byszewski
April 22, 2016
Page 2
Plaintiff may indicate his acceptance of this offer through his counsel, by having his
counsel sign the statement of acceptance below.
Sincerely,
‘Alonzo Wickers IV
DAVIS WRIGHT TREMAINE LLP
Robert B. Carey
Leonard W. Aragon
Hagens Berman Sobol Shapiro LLP
11 West Jefferson Street, Suite 1000
Phoenix, AZ 85003
‘Steve W. Berman
Hagens Berman Sobol Shapito LLP
1918 Bighth Avenue, Suite 3300
Seattle, WA 98101
STATE! oF. AN
Plaintiff JAMES BROWN hereby accepts defendant ELECTRONIC ARTS INC.'s offer made
under Code of Civil Procedure § 998 on the terms stated above,
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PROOF OF SERVICE BY MAIL L.
over the age of 18
Lam employed in the County of Los Angeles, State of California. 1
and not a party to the within action. My business address is Davis Wright Tremaine LLP, Suite
2400, 865 South Figueroa Street, Los Angeles, California 90017-2566.
On June 28, 2016, I served the foregoing document(s) described as: NOTICE OF
PLAINTIFF'S ACCEPTANCE OF CCP § 998 OFFER by placing a true copy of said
document(s) enclosed in a sealed envelope(s) for each addressee named below, with the name and
address of the person served shown on the envelope as follows:
Elaine T. Byszewskt Robert B. Carey Steve W. Berman
Hagens Berman Sobol Shapiro | Leonard W. Aragon Hagens Berman Sobol Shapiro
LLP Hagens Berman Sobol Shapiro | LLP
301 North Lake Avenue LLP 1918 Bighth Avenue, Suite
Pasadena, CA 91101 11 West Jefferson Street, Suite | 3300
Tel: (213) 330-7150 1000 Seattle, WA 98101
Fax: (213) 330-7152 Phoenix, AZ 85003 Tel: (206) 623-7292
Elaine@hbsslaw.com Tel: (602) 840-5900 Fax: (206) 623-0594
Fax: (602) 840-3012
rob@hbsslaw.com ste w.
leonard@hbsslaw.com
I placed such envelope(s) with postage thereon fully prepaid for deposit in the United States
Mail in accordance with the office practice of Davis Wright Tremaine LLP) for collecting and
processing correspondence for mailing with the United States Postal Service. I am familiar with
the office practice of Davis Wright Tremaine LLP, for collecting and processing correspondence
for mailing with the United States Postal Service, which practice is that when correspondence is
deposited with the Davis Wright Tremaine LLP, personnel responsible for delivering
correspondence to the United States Postal Service, such correspondence is, delivered to the United
States Postal Service that same day in the ordinary course of business.
Executed on June 28, 2016, at Los Angeles, California.
x State 1 declare under penalty of perjury, under the laws of the State of California,
that the foregoing is true and correct.
Federal —_I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct and that I am employed in
office of a member of the bar of this Cotirt)gs whose ditection the service
made.
YVETTE M. MERINO
Print Name. I / * ‘Signature
NOTIGE OF ACCEPTANCE OF OFFER TO COMPROMISE
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