SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

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CAROLINA GILDRED, an individual, :

Plaintiff, : INDEX No. 153554/2017

vs. : [PROPOSED] JUDGMENT
MICHAEL D. FOSTER (aka DARREN M. :
FOSTER, an individual,
:
Defendant.
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Plaintiff Carolina Gildred, having commenced this action on April 17, 2017, and the parties

having entered into a Stipulation of Settlement on January 17, 2020 (“Stipulation”), providing that

Defendant Michael D. Foster would remove, depublish and/or take down any and all content over

which he has possession, custody, or control, whether directly or indirectly, concerning Plaintiff,

Mr. Philip T Gildred, any member of Mr. or Mrs. Gildred’s family, Mr. Gildred’s professional,

business or social organizations, and attorneys Seth Rafkin and Jennifer Bogue and Rafkin Esq.

PLLC, on or before February 3, 2020, and that Plaintiff may enter judgment in the amount of

$150,000.00, together with interest thereon from February 10, 2020, without notice pursuant to

CPLR 3215(i), in the event that Defendant Michael D. Foster did not comply with the Stipulation,

and it appearing that Defendant Michael D. Foster did not comply with the Stipulation by

February 3, 2020 and continues not to comply through the date hereof.

NOW, upon application of Rafkin, Esq. PLLC, attorneys for Plaintiff Carolina Gildred, it

is

ADJUDGED that Plaintiff Carolina Gildred shall have judgment and recover of Defendant

Michael D. Foster, having an address of 126 East Broadway #260, New York, NY 10002, the sum
of $150,000.00, together with interest at the rate of 9% per annum thereon from February 10, 2020,

as calculated by the Clerk in the amount of ___________, amount to the sum of $ __________,

and that Plaintiff Carolina Gildred shall have execution therefor.

ENTERED:

By:

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