Kelly I Warner, PLLC.
8283 Hayden Road, Suite 229
Scottsdale, Arizona 85258
Telephone: (480) 33 -9397

Ix.)



 

$11. (Te. tax

KELLY I WARNER, PLLC

8283 N. Hayden Road, Suite 229

Scottsdale, Arizona 85258

Email: (AZ Bar #027418)
Daniel R. Warner, Esq. (AZ Bar 026503)

Email: 

Tel: 480-331-9397

Fax: 1-866-96l-4984

Attorneys for Plaintiff

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA
IN AND FOR THE COUNTY OF MARICOPA

 

MEGAN WELTER an individual; CV2016-004734

Plaintiff,

STIPULATED ORDER FOR

V.
PERMANENT INJUNCTION

JOHN and JANE DOES 1-10 are ?ctitious
persons who may have an interest herein.
ABC PARTNERSHIPS 1-1'0; XYZ
CORPORATIONS 1-10; and DEF
LIMITED LIABILITY COMPANIES 1-10,

Defendants:

 

 

 

 

Pursuant to stipulation of the Parties. and good cause appearing therefore, IT IS
ORDERED, ADJUDGED AND DECREED that:

1. Plaintiff is awarded a permanent injunction against enjoining Defendant
Ryan McMahon. from publishing false and defamatory statements concerning Plaintiff,
and enjoining Plaintiff from publishing false and defamatory statements concerning
Defendant Ryan McMahon, and compelling removal of the uniform resource Iccators
in Exhibit A, attached hereto.

2. Defendant andlor Defendant?s Agents, af?liates, and/or other
personi?entity assisting or enabling Defendant's publication of the below-referenced

Content (collectively "Defendant's Agents"), shall immediately remove from all

 





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websites, search engines, forums, blogs, lists, social media sites, and/or other forums
of mass communication (collectively all negative statements, material,
and/or information pertaining to Plaintiff and/or any agentlaf?liate thereof (the
?Content"), including, but not limited to, the Content located at the following URLs,
attached as Exhibit A, and/or any variations thereof, as well as any search terms
andlor URLs that are related, directly or indirectly, or would be reasonably calculated
to lead. to the Content or any of the URLs. I

3. Defendant admits that all or substantially all of the statements made in
the URLs are false and defamatory.

4. Defendant andlor Defendant's Agents shall immediately remove from all
Forums any and all Content, references to the Content, partial references to the
Content. andlor references to partial Content, including, but not limited to, indexing
URLs, index pages, subpages, inner pages, headers, headings, title tags," H1 tags,
meta tags, deep links, navigation menus, footers, ?lenames, ALT text parameters,
structured data, semantic data, images, PDFs, slideshows, multimedia ?les, and
search suggestions:

5. As it is foreseeable that the above-referenced URLs andlor Content will
be referenced on additional webpages in the future (as a result of indexing, re-
indexing, directory development, search result pages, etc), Defendant andlor
Defendant's Agents shall immediately take all actions, including requesting removal
of the URLs from all Internet search engines, including, but not limited to,
Googie, Yahoo!, and Bing, to remove all such webpages and cache from the

Internet, such that the Content is rendered unsearchable;

 

 

Telephone: (480) 331?9397

Kelly I Warner, PLLC
8283 N. Hayden Road, Suite 229
Scottsdale, Arizona 85258





 

 

6. To the extent Defendants and/or Defendants' Agents are unable to
remove any Content from any Forum, Defendants and/or Defendants? Agents shall
immediately take all reasonable actions requested by Plaintiffs to assist Plaintiffs in
removing such Content and/or having the Content rendered unsearchable;

7. The Parties and their Agents shall not post any Content. defamatory or
negative material or information about each other andior any agent/af?liate thereof on
any Forum;

8. The Parties and their Agents shall not publish (orally in writing) any
Content, defamatory or negative material or information about Plaintiffs and/or any
agentlaf?liate thereof to any third party; and

9. All Parties shall be deemed to have appeared and waive all objections to

Jurisdiction. The Court shall retain jurisdiction to the extent it is necessary amend this
oak] mm?Hl-er' )1 elf: 

144
day of Tun/f? . 2016.

Pee-es

The Honorable Patricia Sta?rr, Judge
Maricopa County Superior Court

order,

DATED this 2 7



 

Kelly I Warner, PLLC
8283 N. Hayden Road, Suite 229
Scottsdale, Arizona 85258
Telephone: (480) 331-9397

Ix.)



 

 

APPROVED AS TO

 

FORM AND CONTENT
a Dated?rz?tgzze
McMahon
Wad. #229

 

WM WM Dated: 

Megan Welt%r

KELLY I WARNER, PLLC

Isl Raeesabba's Mohamed
Raeesabbas Mohamed. Esq.
8283 N. Hayden Rd., Suite 229
Scottsdale, Arizona 85258
Attorney for Plainti?

COPY of the foregoing ?led
electronically on this same date with
the Clerk of the Superior Court.

COPY of the foregoing
mailed on this same date to:

Ry McMal'ionfI
d, #229
Scottsdale, AZ 85258

Isl Anne E. Grif?th
Anne E. Grif?th