ex-10.2

  
 John E. Dolkart, Jr., SBN 259707
 LAW OFFICES OF JOHN E. DOLKART, JR.
 1750 Kettner Blvd., Suite 416
 San Diego, California 92101
 Tel: (619) 501-1083
 Fax: (619) 684-3512
 john@dolkartlaw.com
 

 Attorney for:
 Plaintiffs
 SUPERIOR COURT OF THE STATE OF CALIFORNIA
 COUNTY OF SAN DIEGO – CENTRAL DIVISION
 

 	 	
	 PIONEER GROUP, LLC, a limited liability company; BLACK CAR, INC., a corporation;
 

 Plaintiffs,
 

 vs.
 

 HOLLY BROTHERS PICTURES, INC., a corporation; and DOES 1 through 10, inclusive;
 Defendant.
	 Case No.: 30-2017-00010522-CU-BC-CTL
 

 Assigned for All Purposes
 Hon. Gregory W. Pollack 
 Dept. C-71
 

 STIPULATION APPROVING SETTLEMENT AND ORDER THEREON
 

 

 Complaint Filed: 
 March 2, 2018

	  
	  


 

 STIPULATION
 IT IS HEREBY STIPULATED AND AGREED by and between, Plaintiffs Pioneer Group, LLC and Black Car, Inc. (collectively “Plaintiffs” or individually as “Plaintiff”) and Defendant Holly Brothers Pictures, Inc., (the “Defendant”), collectively referred to as, “the Parties” or a “Party” where context may require and each of them having settled the above entitled matter by written agreement by entry into this Stipulation for Entry of Judgment and Order Thereon (“the Stipulation”) that all claims presented in Plaintiff’s Complaint have been and are now fully settled and resolved to the mutual satisfaction of all Parties pursuant to the terms of that certain written Settlement and Mutual Release Agreement  (the “Settlement Agreement”) by and between the Parties, dated March 21, 2018, a true and correct copy of which is on-file with the court at to which this Stipulation is included as an Exhibit thereto. 
  
 STIPULATION FOR THE ENTRY OF JUDGMENT AND ORDER THEREON
 1
 
 

 

 

 IT IS FURTHER STIPULATED AND AGREED by and between the Parties to dismiss the Entire Action, with prejudice, by the delivery of the executed Request for Dismissal to be filed upon the completion of the items of performance for the Defendant as further provided by the Settlement Agreement.
 IT IS SO STIPULATED.
 

 Dated: March 22, 2018
 PIONEER GROUP, LLC 
 (“Plaintiff”)
 

 

 By: /s/ Michael Caloway
 Michael Caloway, Manager
 

 Dated: March 22, 2018
 BLACK CAR, INC. 
 (“Plaintiff”)
 

 

 By: /s/ Keith Williams 
 Keith Williams, Manager
 

 

 

 Dated: March 22, 2018
 HOLLY BROTHERS PICTURES, INC.
 (“Defendant”)
 

 

 By: /s/ Brent Willson
 Brent Willson,  Chief Executive Officer
  
 

 

 

 

 

 


 STIPULATION FOR THE ENTRY OF JUDGMENT AND ORDER THEREON
 2
 
 

 

 

 

 ORDER
 The Court have read and considered the Stipulation and there being no opposition to the Settlement Agreement proposed thereunder and on proof made to the satisfaction of the Court and good cause appearing therefore:
 IT IS HEREBY ORDERED, ADJUDGED AND DECREED that the settlement and compromise of the above-entitled action pursuant to the terms of the Settlement Agreement, including the issuance of shares of common stock to the Plaintiffs by Defendant pursuant to Section 3(a)(10) of the Securities Act of 1933, as amended, and Corporations Code Section 25017(f)(3) and the stipulation for limited reservation of jurisdiction by the Court as contained therein are approved;
 IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the above-entitled Court has opined that the settlement agreement is fundamentally to all parties and the Court shall retain jurisdiction over the parties hereto to enforce the terms of the Settlement Agreement to the extent required therein.
 

 Dated: April ___, 2018 
 

 ________________________________________
                                           Hon. Gregory W. Pollack
                                         Judge of the Superior Court
 

 

 

 

 

 

 

 

 

 

 


 STIPULATION FOR THE ENTRY OF JUDGMENT AND ORDER THEREON
 3