Professional Documents
Culture Documents
I 3-ov-5823 (JFB)(ARL)
STIPULATION OF SETTLEMENT
Defendants.
2, No later than 120 days prior to Election Day, or any special election for a state, county or
town-wide election, the Office of the Town Attorney shall circulate a memorandum to all to
Town employees advising them that they are prohibited from engaging in any political activity
on behalf of any party or candidate during their working hours, or to utilize any Town property
for such purposes.
3. Within thirty (30) days following the final execution and filing of this Stipulation of
Settlement, plaintiffs' attorney shall return to the firm of Sinnreich Kosakoff & Messina LLP, all
originals and copies of any of the photographs or videos referred to in the Complaint, and all
other photographs and videos relating to the election of November 2013 within his/their
2
and their respective officers, employees, heirs, executors, administrators, successors and assigns,
hereby reciprocally release and discharge the other from all claims, actions, causes of action,
suits, debts, injuries, damages and demands whatsoever relating to (i) the subject matter of the
Complaint, including all claims asserted or which could have been asserted therein; (ii) all claims
arising out of the conduct of any of the defendants with respect to the election of November
2013; and (iii) any alleged deficiency or constitutional infirmity with respect to the provisions
and requirements of Chapter 246-11 of the Town Code of the Town of Oyster Bay, which
Releasor ever had, now has or hereafter can, shall, or may have for, upon, or by reason of any
matter set forth in subsections (i) (ii) or (iii) herein.
6, Simultaneously with the execution and filing of this Stipulation of Settlement, counsel for
all parties shall execute a Stipulation and Order of Dismissal, dismissing this action with
prejudice and without costs by any party as against any other party.
Dated: May 7 , 2015