11 KINSELLA

KINSELLA WEITZMAN
WEITZMAN ISER ISER KUMP
KUMP & & ALDISERT
ALDISERT LLP
LLP
MICHAEL
MICHAEL J. J. KUMP
KUMP (SBN
(SBN 100983)
100983)
2
2 mkump@kwikalaw.com
mkump@kwikalaw.com
JONATHAN
JONATHAN P. P. STEINSAPIR
STEINSAPIR (SBN(SBN 226281)
226281)
3
3 jsteinsapir@kwikalaw.com
jsteinsapir@kwikalaw.com
NICHOLAS
NICHOLAS C. C. SOLTMAN
SOLTMAN (SBN(SBN 277418)
277418)
4 nsoltman@kwikalaw.com
nsoltman@kwikalaw.com
808
808 Wilshire
Wilshire Boulevard,
Boulevard, 3rd
3rd Floor
Floor
55 Santa
Santa Monica,
Monica, California 90401
California 90401
Telephone:
Telephone: 310.566.9800
310.566.9800
66 ]]Facsimile:
Facsimile: 310.566.9850

77 Attorneys
Attorneys for
for Plaintiffs
Plaintiffs PRINCE
PRINCE HARRY,
HARRY,
THE
THE DUKE
DUKE OF OF SUSSEX
SUSSEX ANDAND MEGHAN,
MEGHAN,
88 THE
THE DUCHESS
DUCHESS OF OF SUSSEX
SUSSEX

99 SUPERIOR COURT OF
SUPERIOR COURT OF THE
THE STATE
STATE OF
OF CALIFORNIA
CALIFORNIA
10
10 COUNTY
COUNTY OF
OF LOS
LOS ANGELES
ANGELES -
- WEST DISTRICT
WEST DISTRICT
11

12
12 PRINCE
PRINCE HARRY,
HARRY, THETHE DUKE
DUKE OF
OF SUSSEX,
SUSSEX, Case No. 20SMCV00975
Case No. 20SMCV00975
AND
AND MEGHAN,
MEGHAN, THETHE DUCHESS
DUCHESS OF
OF
13 SUSSEX,
13 SUSSEX, individuals,
individuals, Hon. Craig D.
Hon. Craig D. Karlan,
Karlan, Dept. N
Dept. N
Electronically Received 10/08/2020 09:26 AM

14
14 Plaintiffs,
Plaintiffs, [PROPOSED]
[PROPOSED] STIPULATED
STIPULATED
PERMANENT INJUNCTION
PERMANENT AND
INJUNCTION AND
15
15 vs.
vs. FINAL
FINAL JUDGMENT
JUDGMENT

16
16 JOHN
JOHN DOE
DOE 1,1, an
an individual
individual whose
whose name
name isis
unknown,
unknown, JOHN
JOHN DOE DOE 2,2, an
an individual
individual or
or Action
Action Filed:
Filed: July
July 23,
23, 2020
2020
17
17 entity
entity whose
whose name
name is is unknown,
unknown, and
and Trial
Trial Date:
Date: None
None Set
Set
JOHN
JOHN DOES
DOES 33 through
through 100,
100, inclusive,
inclusive,
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18
Defendants.
Defendants.
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PERMANENT
PERMANENT INJUNCTION AND FINAL
INJUNCTION AND FINAL JUDGMENT
JUDGMENT
 1 PERMANENT INJUNCTION

2 Pursuant to the Stipulation

Stipulation for
for (1)
(1) Entry
Entry of Stipulated Permanent
of Stipulated Injunction and
Permanent Injunction and Final
Final

3 Judgment and
Judgment and (2)
(2) Retention
Retention of
of Jurisdiction
Jurisdiction Pursuant
Pursuant to
to Code of Civil
Code of Civil Procedure
Procedure § 664.
664. 66 executed

4 and filed by Plaintiffs Prince Harry, The Duke of Sussex, and Meghan, The Duchess of Sussex, on

5 the one hand, and Defendant Xl 7, Inc., on the other hand, and for good cause appearing therefor:

6 IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT:

7 A. The Court has jurisdiction over the subject matter in this dispute and the parties

8 herein. Venue is proper in this Judicial District. The Court finds that there is a factual and legal

9 basis for entry of this Judgment and Permanent Injunction and for the enforceability of this

10 Judgment and Permanent Injunction as set forth herein.

11 B. Plaintiffs are the parents of the minor child, Archie Harrison Mountbatten-Windsor

12 (Archie).

13 D. Defendant Xl 7, Inc. is the operator of Xl 7 Agency, a celebrity photo agency,

14 which distributes photos and videos to media outlets throughout the world.

15 E. In July 2020, Plaintiffs learned that someone was shopping photographs of Archie

16 that had been taken of activities on the private grounds of the Plaintiffs' private residence,

17 unbeknownst to the Plaintiffs.

18 F. Discovery taken in this Action has revealed that the photographs at issue were

19 taken by Xl 7 in July 2020, and depict Archie with his maternal grandmother on the private garden

20 grounds of Plaintiffs' private residence ("the Photographs") and then offered for sale to buyers in

21 1

the United States and Europe.

22 Accordingly, for good cause shown, the Court enters Judgment in this Action in favor of

23 Plaintiffs and against Xl 7 as follows:

24 1. Xl 7, Inc., and its respective affiliates (including but not limited to Xl 7 Agency,

25 Xl 7 Online, and Navarre Media Enterprises, Inc.), agents, managers, directors, officers,

26 employees, and attorneys, and all persons acting in concert or participation with him, her, it or

27 them, are hereby permanently enjoined and restrained from engaging in, committing, or

28 performing, directly or indirectly, any and all of the following acts, in perpetuity:

2
PERMANENT INJUNCTION AND FINAL JUDGMENT
 1 a. publicly exhibiting, licensing, selling, distributing, displaying, publishing,

2 or using any of the Photographs in any way;

3 b. taking, commissioning, or accepting any photographs of Plaintiffs and their

4 son taken in any private residence or the surrounding private grounds, which were obtained

5 through use of a zoom or telephoto lens, or drones; and

6 c.
C. aiding, abetting, assisting, inducing, or participating with others in the acts

7 prohibited and enjoined herein.

8 2. Xl 7, Inc., and its respective affiliates (including but not limited to Xl 7 Agency,

9 Xl 7 Online and Navarre Media Enterprises, Inc.), agents, managers, directors, officers,

10 employees, and attorneys, and all persons acting in concert or participation with him, her, it or

11 them, are hereby ordered to:

12
12 a. turn over to Plaintiffs all originals and all copies (physical and digital) of

13 : the Photographs with original metadata intact;

I

13
i

14 b. identify to Plaintiffs all recipients, including but not limited to Xl Ts agents

15 and publishers, of the Photographs ("the Recipients"); and

15
16 c. instruct the Recipients to delete the Photographs from their archives or

17 databases and never to license, distribute or publish the Photographs.

17
18 II I
18
19 I II
20 I II
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21 I II
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22 II I
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23 II I
23
24 II I
24 I

25 II
25 I III
26 II I
27 Ill
27 II I
28 II I

3
PERMANENT INJUNCTION AND FINAL JUDGMENT
 1 3. Pursuant to the parties' stipulation under California Code of Civil Procedure

2 § 664.6, this Court shall retain jurisdiction over this action and the parties for the purpose of

3 enforcement of this Permanent Injunction and the Settlement Agreement entered into between the

4 parties. Therefore, Plaintiffs may apply to this Court in the future for such further orders and

5 directions as may be necessary or appropriate to resolve any issues out of a claim of violation of or

6 noncompliance.

7 IT IS SO ORDERED, ADJUDGED AND DECREED.

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4
PERMANENT INJUNCTION AND FINAL JUDGMENT
 1 PROOF OF SERVICE

2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

3 At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of Los Angeles, State of California. My business address is 808 Wilshire
4 Boulevard, 3rd Floor, Santa Monica, CA 90401.

5 On October 8, 2020, I served the following document(s) described as [PROPOSED]

STIPULATED PERMANENT INJUNCTION AND FINAL JUDGMENT on the interested
6 parties in this action as follows:

7 Francois Navarre
X17, Inc.,
8 101 South Robertson Blvd.
Los Angeles, CA 90048
KINSELLA WEITZMAN ISER KUMP & ALDISERT LLP

9
BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the persons
10 at the addresses listed above or on the attached Service List and placed the envelope for collection
and mailing, following our ordinary business practices. I am readily familiar with Kinsella
TEL 310.566.9800 • FAX 310.566.9850

11 Weitzman Iser Kump LLP's practice for collecting and processing correspondence for mailing.
808 WILSHIRE BOULEVARD, 3RD FLOOR
SANTA MONICA, CALIFORNIA 90401

On the same day that the correspondence is placed for collection and mailing, it is deposited in the
12 ordinary course of business with the United States Postal Service, in a sealed envelope with
postage fully prepaid.
13
I declare under penalty of perjury under the laws of the State of California that the
14 foregoing is true and correct. Executed on October 8, 2020 at Los Angeles, California.

15

16
Candace E. Hoffman
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