Settlement Agreement Between the JRTNNC and the JRTCGB

This agreement is made between The Jack Russell Terrier Club of Great Britain ("JRTCGB") and The Jack Russell Terrier Network of Northern California ("JRTNNC").

1.Effective January 1, 2001, the JRTCGB will eliminate from its constitution, bylaws, affiliate agreements, and other rules of governance and procedure the so called "conflicting organization rule", by which in the past the JRTCGB and its affiliates have dealt with owners and Jack Russell terriers that have been associated with, in one way or another, kennel clubs and other organizations, including other terrier clubs, that have rules, standards or procedures that the JRTCGB has felt were not consistent with its own.

2.On the performance by the JRTCGB of paragraph 1 of this agreement, the JRTNNC will dismiss the JRTCGB without prejudice from the litigation entitled The Jack Russell Terrier Network of Northern California v. The Jack Russell Terrier Club of America, United States District Court, Northern District of California, No. C-98-20932-JW ("the federal action"). The JRTNNC will undertake to acquire the consent of the other plaintiffs in the federal action to the dismissal and is confident of acquiring it.

3.Copies of the JRTCGB's constitution, bylaws and affiliate agreement effective as of January 1, 2001 are attached.

4.The JRTNNC will not again name the JRTCGB in the federal action or in any other proceedings unless and until the JRTCGB adopts, implies or informally enforces provisions of its constitution, bylaws or other rules of governance or procedure that constitute (a) the identical rule in words or fuction or (b) the substantial equivalent of the rule eliminated under Paragraph 1 above.

5.For a period of three years from the date of this agreement, the JRTCGB will not engage in activity that under American law may constitute a boycott under American law of the JRTNNC or any of its members. The JRTCGB and the JRTNNC will open, maintain, and support an exchange of views and experiences, which shall include regular visits among its board members, officers, and members, with the aim of avoiding a boycott in form or substance of the JRTNNC and of preserving, protecting, and better understanding the Jack Russell terrier and its physical strengths and weaknesses. This exchange of visits and views shall also include efforts to eliminate misunderstandings that arise between the clubs and their members by periodic visits of members between their countries, liaison between their governing groups, exchange of judges for dog trials, and other means to share the common experience of owning, breeding, hunting, protecting, and showing Jack Russell terriers. Toward this end, the JRTCGB will name a "client representative" to deal directly with the JRTNNC and its members, including but not limited to Scott Kauffman, Tory Brieant and Malcolm Misuraca. Barrie Wade will until further notice be the client representative for the JRTCGB, and Scott Kauffman will be the client representative for the JRTNNC.

6.It is the intention of this agreement that the main costs, if not the sole cost, of the exchange described in paragraph 5, above, shall be borne by funds raised by the JRTNNC through its best efforts.

7.Within the exchange provided in paragraph 5 above, the JRTCGB will, if reasonable necessary in the view of the JRTNNC, provide one of its officials to travel to the United States to appear at a settlement conference or settlement mediation in the federal action, which is aimed at finding ways and means to settle that action on a basis appropriate to avoid a violation of the American law and the central purpose of legitimately protecting the Jack Russell terrier. The JRTCGB will likewise as necessary provide on it its officials to appear at a trial in the federal action should it reach the point where the JRTNNC and the JRTCA have failed to also reach a settlement agreement. The JRTCGB may provide more than one official for these exchanges is they deem it to be appropriate. All cost to the JRTCGB under this paragraph shall be paid or reimbursed by the JRTNNC.

8.The parties to this agreement will submit the agreement for the approval of the U.S. District Judge in the federal case, to be made an order of the Court, but it shall be effective when executed by the parties.

9.Each party shall bear its own attorneys fees and costs in the federal action, except as the JRTNNC has elsewhere in this agreement agreed to pay certain cost.

10.This agreement shall be executed in five original counterpart copies, one for the U.S. District Judge in the federal case, one for the JRTCGB, one for the JRTNNC, and one each for their lawyers, whose names are set forth below and who shall execute this agreement to signify their agreement to it.

11.This agreement shall be I interpreted under California law and the federal law of the United States. The parties to this agreement will perform it in good faith and fair dealing toward each other and with the objective to enhance their dealings with each other.

12.Nothing in this settlement agreement or any action pursuant to it shall be used in any lawsuit as evidence either to support or to counter any claim or to support jurisdication over the JRTCGB.

Dated: December 19, 2000


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