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Mark McKenna v. Rodolfo Molina - Stipulation for Final Judgment and Permanent Injunction - Google-Deindexing-Removal Request per Google’s Lumen Database at lumendatabase.org
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Mark McKenna v. Rodolfo Molina - Stipulation for Final Judgment and Permanent Injunction
Mark McKenna v. Rodolfo Molina - Stipulation for Final Judgment and Permanent Injunction - Google-Deindexing-Removal Request per Google’s Lumen Database at lumendatabase.org
Mark McKenna v. Rodolfo Molina - Stipulation for Final Judgment and Permanent Injunction - Google-Deindexing-Removal Request per Google’s Lumen Database at lumendatabase.org
AUG 2.5 2015
IN THE SUPERIOR COURT OF FULTON COUNTY
STATE OF GEORGIA
DePuy =
BERS
FULTON COUNTY GaCOURT
Mark Mekenna ) CASE NO. 2015CV264069
)
Plaintifts, )
v, ) JUDGE: NEWKIRK
)
Rodolfo Molina, )
) STIPULATION FOR FINAL
Defendant. ) JUDGMENT AND PERMANENT
) INJUNCTION
This Stipulation for Final Judgment and Permanent Injunction (“Stipulation”) is entered
info by and between Plaintiff Mark Mckenna. (“Plaintiff”) and Defendant Rodolfo Molina
(‘Defendant”), Plaintiff and Defendant collectively referred to herein as the “Parties.” The
Parties hereby stipulate that:
1. This Court has jurisdiction of the subject matter hereof and of the Parties to this
Stipulation;
2. Defendant received a copy of the Summons and Complaint at his residence by
hand delivery in August, 2015, and acknowledges service of said Summons and Complaint,
3. Defendant unlawfully published statements about Plaintiff on the Internet, which
are false, defamatory, and constitute libel per se, and that his doing so was wanton, willful, and
malicious,
4, Defendant agrees to being enjoined from further false publications regarding
is false statements from the Internet;
Plaintiff, and in taking the necessary actions to remove
5. The attached Final Judgment and Permanent Injunction (the “Judgment”) may be
centered by any judge of the Fulton County Superior Court and should be entered by the Court in
furtherance of this Stipulation;
6. The Parties hereby waive their right to move for a new trial or otherwise seek to
set aside the Judgment through any collateral attack, and further waive their right to appeal from
e yo 7the Judgment, except that the Parties both agree that this Court shall retain jurisdiction for the
enforcement of, compliance with, or punishment’ of violations of the Judgment attached
herewith;
7. Defendant will accept service of any Notice of Entry of Judgment entered in this
action by delivery of such notice via regular mail to his residence; and
8. Each party is to bear their own costs and attorney's fees.
ITIS SO STIPULATED
Dated: August 20, 2015
Grace Tillman (State Bar No. 134243)
irney for Mark Mckenna
Richard C. Wayne & Associates, P.C.
Peachtree | 25th Building
1720 Peachtree Street NW, Suite 118
Atlanta, Georgia 30309
Telephone: (404) 231-1444
Dated: August {f, 2015 hAj{L—
~ folfo MolinaIN THE SUPERIOR COURT OF FULTON COUNTY.
STATE OF GEORGIA
Mark Mckenna ) CASE NO. 2015CV264069
)
Plaintiffs, )
v. ) JUDGE: Newnes
)
Rodolfo Molina, )
)
Defendant. )
)
HIBIT A — AFFIDAVIT OF RODOLBO MOLINA
State of Georgia )
) ss
Countyof___ sd)
I, Rodolfo Molina, first being duly sworn, state the following:
1. Lam over 18 years of age, have personal knowledge of the facts set forth below, and am
otherwise fully competent to testify to the matters set forth herein
2. 1 published several false and defamatory statements anonymously about Mark Mckenna
on the Internet website RipoffReport.com using the aliases/names “mlawson.” I knew the
statements were completely false when I published them and published them
intentionally to cause harm to Mark Mckenna.
3, The false statements include, among others, that:
i, 1 bought my “fiancé a gift certificated at Shape
‘Wellness
(www shaptemed.com)” about a year before I published the Ripoff Report
ii, My fiancé and I received “a few followup calls” from Mr. Mckenna that “led to
a complete stalking case, reported with the Atlanta Police Department.”
iii, To protect my fiancé, “pulled public records from the Buckhead precinct on Dr.
Stanton Mark Mckenna”, which showed that Mr. Mckenna had “been arrested
numerous times for stalking and ... even gave a girls a BLACK EYE”.
(Ar WOW