Fascism in America:
"Settlement Demand
Plaintiffs demand a stipulated judgment providing as follows:
a. entry of a permanent injunction prohibiting Delfino and Day from making further statements or commentary about, or impersonating, in any form, whether oral or written, including but not limited to on the Internet, any of the following: Felch; any of Felch's family members; Zdasiuk; any of Zdasiuk's family members; Varian Semiconductor; any of Varian Semiconductor's employees, officers, directors, attorneys, or any of their family members; Varian Medical; or any of Varian Medical's employees, officers, directors, or attorneys, or any of their family members.
b. entry of a permanent injunction requiring Delfino and Day to disable all web sites and web pages under their control containing information about Plaintiffs or this lawsuit, and to refrain from posting, further such information, including but not limited to deposition transcripts and commentary thereon;
c. entry of a permanent injunction prohibiting Delfino and Day from telephoning, emailing, writing to, approaching within 100 feet of, or otherwise contacting or harassing any of the following persons: Zdasiuk, Felch, Richard Levy, Richard Aurelio, Jim Fair, Ron Powell, Kathy Hibbs, Jeff Wright, Craig Moro, Jane Crisler, Joseph Phair, Lynne Hermle, Matthew Poppe, or any of their family members;
d. an appropriate enforcement mechanism, such as a liquidated damages provision that applies in case the injunction is violated;
e. a written, signed, and videotaped statement by Delfino and Day acknowledging their responsibility for the Internet messages they are alleged to have posted and apologizing to Plaintiffs for the harm Delfino and Day have inflicted upon Plaintiffs;
f. a monetary payment by Delfino and Day, jointly and severally, of $300,000 to Felch, $300,000 to Zdasiuk, $300,000 to Varian Medical, and $300,000 to Varian Semiconductor;
g. the dismissal of Delfino's cross-complaint with prejudice;
h. a waiver by Delfino of his right to appeal the dismissal of cross-claims that have already been dismissed;
i. the dismissal of the defendants' appeal of the denial of their SLAPP motions, and the waiver of their right to file any other appeal related to Plaintiffs or this lawsuit; and
j. a general release by Delfino and Day of all claims they might have, known or unknown, against Plaintiffs and related persons and entities."
geocities.com
See you at the trial on October 22nd 8:30 am in Santa Clara County Court! |
