wee a aw sw 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. DWT 296428622 0058278-000008,Boo 6 a ow 2 wp ul 1 13 14] 15 16) 1 18 19 24) 21 22 23| 24 25) 26 21| 28| 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 DWT 296428602 0058278-000028 niesEXHIBIT Ai Davis Wright ERC aee remaine Lp ‘onzo Wikre saeco oe ziaess one sercowetangont com 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. ‘wr aarssv7 cose aco oat | Soe Sige. [eee | Meigen oe ete aonBlaine 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, Dwr aa7sey7east27 sontwe we a aw 10| 4 12| B 14] 15 16) vy 18) 19| 20| 21] 22] 23] 2a| 25] 26} 21] 28) 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 Dwr 2s6eze6ov2.0n58278-000028