FILED: NEW YORK COUNTY CLERK 01/30/2018 01:04 PM INDEX NO.

651008/2016
NYSCEF DOC. NO. 108 RECEIVED NYSCEF: 01/30/2018

SUPREME COURT OF THE STATE OF NEW YORK

NEW YORK COUNTY

TRAVELZOO INC.,

Plaintiff, Index No. 651008/2016

-against-
Justice David B. Cohen

FRESH TRIPS LLC, TIMOTHY WOZNIAK, and

GEORGE WOZNIAK,

Defendants.

WHEREAS, Defendants filed a motion to dismiss on February 16, 2017 (the "Motion

Dismiss"
to Dismiss"), and the motion has been fully briefed, and

WHEREAS, oral argument on the motion was adjourned to allow the parties time to

finalize a settlement, and

WHEREAS, the parties to this action have executed a Settlement Agreement and

Agreement"
Release (the "Settlement Agreement"), dated January 30, 2018, and

WHEREAS, under the Settlement Agreement, Defendants have agreed to make an

upfront payment of $5,000, followed by three installments of $30,000 each, to be wired to

Defendants'
counsel by February 15, 2018, March 15, 2018, and April 15, 2018, respectively,

and,

WHEREAS, Defendants made the upfront $5,000 payment on January 30, 2018,

IT IS HEREBY STIPULATED AND AGREED by and between the undersigned

counsel as follows: oral argument on the Motion to Dismiss, all other proceedings, and all

disclosure are stayed until April 30, 2018.

I
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FILED: NEW YORK COUNTY CLERK 01/30/2018 01:04 PM INDEX NO. 651008/2016
NYSCEF DOC. NO. 108 RECEIVED NYSCEF: 01/30/2018

Dated: New York, New York

January 30, 2018

SHER TREMONTE LLP HUNG G. TA, ESQ. PLLC

By: /s/_Yonatan Y. Jacobs__ By: /s/ Hun

_/s/_Hung G. Ta
Michael Tremonte Hung G. Ta
Yonatan Y. Jacobs 250 Park Avenue
90 Broad Street, 23rd Floor 7th Floor
New York, New York 10004 New York, New York 10177
Tel: 212.202.2600 Tel: 646.453.7288
yjacobs@shertremonte.com hta@hgtlaw.com

Counsel for Defendants Counsel for Plaintiff Travelzoo Inc.

Fresh Trips LLC, Wozniak,
Wozniak'Timothy
and George Wozniak

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