I

Declaration of James F. Zahradka 11

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KAMALA D. HARRIS Attorney General of California JACQUELINE DALE Supervising Deputy Attorney General MARIA ELLINIKOS (SBN 235528) Deputy Attorney General

455 Golden Gate Avenue, Suite 11000 San Francisco, CA 94102 Telephone: (415) 703-5500 Fax: (415) 703-5480 E-mail: Maria.Ellinikos@doj.ca.gov

Attorneys for TI-IE PEOPLE OF THE ST ATE OF CALIFORNIA

SUPERIOR COURT OF TI-IE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

STATE OF CALIFORNIA, ex. rel., SUSIE KAPLAR,

Plaintiff,

v.

CALIFORNIA VIRTUAL ACADEMY@ LOS ANGELES, K12 INC. D/B/A/ DELAWARE K12 INC., and DOES 1 through 100, inclusive ,

Defendants.

Case No. BC483914 [Under Seal]

DECLARATION OF JAMES ZAHRADKA

Dept: 50 Judge: The Hon. Teresa A. Beaudet Trial Date: None Set Action Filed: May 2, 2012

I, James Zahradka, declare as follows:

I. I am a Deputy Attorney General with the California Department of Justice, Office of

the Attorney General. Except as otherwise stated, I have first-hand knowledge of the facts set

forth herein, and if called as a witness, I could and would competently testify thereto.

2. The complaint in this action was filed by the qui tam plaintiff on or about May 1,

2012. The complaint was filed under seal as required by the California False Claims Act (Gov.

Code.§ 12652. subd. (c)(2)).

3. On July 8, 2016, concurrently with this declaration, the Attorney General's Office is

filing its Notice of Intent to Intervene for the purpose of setlling this action.

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4. Attached as Exhibit A is a true and correct copy of the executed Settlement

Agreement.

5. I declare under penalty of perjury under the laws of the S tate of California that the

foregoing is true and correct.

Executed this~th day of July, 2016 at Los Angeles, California

SA20 12305067

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Declaration of James F. Zahradka ll

SETTLEMENT AGREEMENT AND RELEASE

I. PARTIES

This Settlement Agreement and Release ("Settlement Agreement") is entered into by the

People of the State of California, acting through the California Department of Justice, Office of

the Attorney General ("AGO"); Qui Tam Plaintiff Susie Kaplar ("Qui Tam Plaintiff''); and

K 12 Inc. ("K 12") and the California Virtual Academies (hereafter collectively referred to

as "CAVA" or the "CAVA Schools") 1, through their authorized representatives (hereafter

collectively referred to as the "Parties").

11. PREAMBLE

A. On May ! , 20 !2, the Qui Tam Plaintiff filed a qui tam action under seal in Los

Angeles County Superior Court, captioned State ofCalifornia ex rel. Kaplar v. Ca/i}Ornia

Virtual Academy@ Los Angeles, Kl 2 Inc. DIE/A Delaware Kl 2 Inc., and Does 1 through 100,

inclusive, court case number BC4839 l 4 ("Litigation"). In the under seal Litigation, the Qui

Tam Plaintiff asserted causes of action under the California False Claims Act (Cal. Gov't Code

§§ 12650 et seq.). The Qui Tam Plaintiff alleged that Kl2 and the CAVA Schools violated the

False Claims Act by submitting inflated claims for attendance funding to the State and

dismissing the Qui Tam Plaintiff from her employment.

B. The AGO, which received a copy of the Qui Tam Plaintiffs under seal complaint,

investigated K 12 's and the CAVA Schools' attendance practices (the "Investigation").

C. During the Investigation, the AGO reviewed, among other things, K 12's and the

CAVA Schools' reporting and submission of attendance and attendance-related figures to the

State for purposes of obtaining State funding, and any associated tracking, recording, accounting,

claiming, reporting, or training relating to attendance and attendance-related funding from the

State; K 12's or CAVA's preparation and submission of Funding Determination Forrns to the

State; and K12's and the CAVA schools' eligibility to obtain Stat~ funding based upon the

1 The CA VA Schools include CA VA@ Fresno, CAVA@ Jamestown, CAVA@ at Kings, CAVA@ Los Angeles, CA VA@ Maricopa, CA VA High School@ Maricopa, CA VA@ San Diego, CA VA @ San Joaquin, CAVA@ San Mateo, CA VA@ Sonoma, CA VA@ Sutter, [nsight@ San Joaquin, Insight@ San Diego, and iQ Academy - Los Angeles.

submission of"Average Daily Attendance" (hereafter collectively referred to as the "Covered

Conduct"). 1

D. Kl 2 and the CA VA Schools deny any and all liability and wrongdoing. K !2

and the CA VA Schools believe that their conduct was at all times !awful and in compliance with

applicable statutory and regulatory requirements and in the best interest of their students and their

families.

E. This Settlement Agreement shall constitute neither an admission of liability by

K12 or the CAVA Schools nor a concession by the AGO or the Qui Tam Plaintiff that any

part of the Qui Tam Plaintiffs Complaint or the investigation lacks merit. This Settlement

Agreement does not constitute or contain any statement or interpretation of law or finding of

fact. This Settlement Agreement is not intended to be used to form the basis of any

disqualification of K 12 or the CAVA Schools from state or federal funding. Neither this

Settlement Agreement nor any payment hereunder may be used as evidence of any liability

of any sort regarding K 12 or the CAVA Schools. To the extent permitted by law, a!l

communications relating to the negotiations of this Settlement Agreement shall remain

confidential. No one other than a Parly lo this Settlement Agreement is intended to receive

any right or benefit under it or to have standing to enforce any of its provisions.

Ill. TERMS AND CONDITIONS

Now, therefore, in reliance on the representations contained herein and in

consideration of the mutual promises, covenants, and obligations set forth in this Settlement

Agreement, and for good and valuable consideration as stated herein, the Parties agree as

follows:

A. Kl2 agrees to pay, Within thirty (30) business days after the Effective Date of this

Settlement Agreement (as defined in Section flLR.), a total sum of$2.5 million ($2,500,000) in

settlement of all claims to be released by the People of the State of California and $ 8 O, O O O

:i The effectiveness of this Settlement Agreement is contingent upon the entry of the final judgment in settlement ofa matter stemming from an investigation ofK 12 by the California Department of Justice's Bureau of Children's Justice. fftha! Judgment is not entered, this Settlement Agreement is null and void.

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1 n sett 1em e n t o f a 11 add i ti o n a I cl a i m s to be re I eased by the Qui

Tam Plaintiff under this Settlement Agreement (the "Settlement Amount").

1. K 12 shall pay the $2.5 million ($2,500,000) to the AGO by electronic

funds transfer pursuant to the written instructions provided in Appendix A. The AGO and the Qui

Tam Plaintiff shall resolve the Qui Tam Plaintiffs share of the AGO's recovery pursuant to

Government Code Section l 2652(g)(3) separately and outside of this Settlement Agreement. All

Parties agree that the issue of the Qui Tam Plaintiffs share shall not preclude entry of this

Settlement Agreement, enforcement of it, or the mutual releases contained herein. Rather, the

issue of the Qui Tam Plaintiffs share is entirely a matter to be handled between the AGO and the

Qui Tam Plaintiff, with motion practice before the Cou1t if necessary.

2. K 12 shall pay, within thirty (30) business days after the Effective Date of

this Settlement Agreement, attorneys fees and costs in the amount of$30,000 to Qui Tam

Plaintiff.

3. Kl2 shall pay, within thirty (30) business days after the Effective Date of

this Settlement Agreement, to Qui Tam Plaintiff$50,000 in release of her employment related

claims in the Litigation.

4. All Parties agree that this Settlement Agreement constitutes a full and

complete resolution of the Litigation and Investigation, and waive any further requests for

interest, expenses, costs, or attorneys' fees among or between them arising out of the Litigation or

lnvestigaLion.

B. Subject to the exceptions in Section !ILE. below, conditioned upon Kl2's full

payment of the Settlement Amount, the People of the State of California hereby release,

discharge, and covenant not to sue Kl 2 and the CAVA Schools, together with their current and

former directors, officers, employees, shareholders, parents, partners, agents, transferees,

predecessors in interest, successors in interest, subsidiaries, affiliates, and assigns with respect to

any and all civil claims the People of the State of California have or may have related to the

Covered Conduct under any Jaw or legal or equitable theory, including but not limited to the

California False Claims Act (Cal. Gov't Code§§ 12650 et seq.), Unfair Competition Law (Cal.

Bus. & Prof. Code §§ 17200 et seq.), False Advertising Law (Ca!. Bus. & Prof. Code §§ I 7500 et

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seq.), Securities Laws, or any other statute or regulation, and including but not limited to the

common law theories of payment by mistake, mistaken receipt, unjust enrichment, negligent

misrepresentation, intentional misrepresentation, breach of contract, or fraud.

C. Conditioned upon K!2's fu!l payment of the Settlement Amount and CA VA 's

commitments herein:

l. The Qui Tam Plaintiff and her attorney(s) hereby covenant not to sue and

release K !2 and the CAVA Schools, together with their current and former directors, officers,

employees, shareholders, parents, partners, agents, transferees, predecessors in interest, successors

in interest, subsidiaries, affiliates, and assigns from any and all claims, rights, demands, suits,

matters, issues, actions or causes of action, liabilities, damages, losses, obligations, and

judgments of any kind, including any related to any allegations in the Qui Tam Plaintiffs

Complaint or the Covered Conduct, from the beginning of time through the Effective Date of this

Settlement Agreement, whether known or unknown, contingent or absolute, suspected or

unsuspected, disclosed or undisclosed, matured or unmatured, for damages, injunctive relief, or

any other remedy against K 12 and the CAVA Schools.

2. Notwithstanding any term of this Settlemenl Agreement, the Qui Tam

Plaintiff does not release K 12 and the CAVA Schools for any breach of this Settlement

Agreement, or for any fraud in its inducement.

D. The Qui Tam Plaintiff acknowledges that she has been advised by her attomey(s)

of the contents and effect of Section 1542 of the California Civil Code ("Section 1542"), which

reads:

A GENERAL RELEASE DOES NOT EXTEND TO CLATMS WHTCH THE CREDTTOR DOES NOT KNOW OR SUSPECT TO EXIST TN HTS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHTCH lF KNOWN BY HTM OR HER MUST HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WTTH THE DEBTOR.

As a condition of this Settlement Agreement, with full awareness and understanding of Section

[542, the Qu; Tam Plaintiff hereby expressly waives with respect to this Settlement Agreement

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any and all provisions, rights, and benefits conferred on her by Section 1542 (or any analogous

state Jaw or federal law or regulation).

E. Notwithstanding any term of this Settlement Agreement, the People of the

State of California specifically do not release any person or entity from, or renounce any action

or remedy for, the following claims or liabilities:

! . Any civil, criminal, or administrative liability arising under Title 26,

U.S. Code (Internal Revenue Code), or California's Taxation and Revenue Code.

2. Any !iability to the State of California (or its agencies) for any conduct

other than that released above.

3. Any liability, other than related to the Covered Conduct, for express or

implied warranty claims or other claims for defective or deficient products or services,

including, but not limited to, quality of goods and services.

4. Any liability, other than related to the Covered Conduct, for failure to

deliver goods or services due or to pay for goods and services.

5. Any liability for breach of this Settlement Agreement or fraud in its

inducement.

F. This Settlement Agreement does not release or bar any rights or causes of action

arising from the Covered Conduct belonging to any state agency other than the Attorney

General, whether or not in the name of the People of the State of California, including but not

limited to the California State Controller's Office, the California Department of Education, or the

State Board of Education.

G. Except as expressly provided to the contrary in this Settlement Agreement, each

Party shall bear its own legal and other costs and expenses incurred in connection with this

matter, the Investigation, and the Litigation, including the preparation and performance of this

Settlement Agreemenl. Without limitation, K!2 and the CAVA Schools will not attempt to

recoup any such costs or expenses from the AGO or the Qui Tam Plaintiff.

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1-l. The AGO and the Qui Tam Plaintiffsha!!, within five business days following

receipt ofpaymenl of the Settlement Amount set forth in Section III.A. above, dismis~ the

Litigation with prejudice. The AGO and the Qui Tam Plaintiff agree to take all steps to obtain

any court-needed approval of dismissal. If complete dismissal is not achieved within 60 days of

the Effective Date, K 12 and the CAVA schools may demand repayment of the Settlement

Amount, which shall not be withheld by the AGO and The Qui Tam Plaintiff, and will have the

option of terminating this agreement or obtaining an alternative resolution with the AGO and Qui

Tam Plaintiff.

I. Kl 2 and the CAVA Schools represent that this Settlement Agreement is freely

and voluntarily entered into without any degree of duress or compulsion whatsoever.

J. The AGO and the Qui Tam Plaintiff represent that this Settlement Agreement is

freely and voluntarily entered into without any degree of duress or compulsion whatsoever.

K. This Settlement Agreement is governed by the laws of the State of California.

L. For purposes of construction, this Settlement Agreement shall be deemed to

have been drafted by all Parties to this Settlement Agreement and shall not, therefore, be

construed against any Party for that reason in any subsequent dispute.

M. This Settlement Agreement constitutes the complete agreement between the

Parties in resolving the Litigation with prejudice. This Settlement Agreement may not be

amended except by written consent of the Parties.

N. The individuals signing this Settlement Agreement on behalf of Kl 2 and the

CA VA Schools represent and warrant that they are authorized by Kl2 and the CA VA Schools

to execute this Settlement Agreement. The State signatories represent that they are signing

this Settlement Agreement in their official capacities and that they are authorized to execute

this Settlement Agreement.

0. This Settlement Agreement may be executed in counterparts, each of which

constitutes an original and al! of which constitute one and the same Settlement Agreement.

P. This Settlement Agreement is binding on Kl2's and the CAVA Schools'

successors, transferees, heirs, and assigns.

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Q. This Settlement Agreement is binding on the Qui Tam Plaintiffs successors,

transferees, heirs, and assigns.

R. This Settlement Agreement is effective on the date of signature of the last

signatory lo this Settlement Agreement (the "Effective Date"). Facsimiles and other images of

signatures, including electronically transmitted signatures provided via email, shall constitute

acceptable, binding signatures for purposes of this Settlement Agreement.

[SIGNATURES ON NEXT PAGE]

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PEOPLE OF Tl! ESTATE OF ('ALI H)RNIA

Kamala D. Harris Attorney Gcncrnl of the State ofCalifornia

By

QUI TAM PLAINTIFF

Dnlcd: . 2016 13y: -----------------­Susie Kaplar

Approved as to Form:

llecic'd, ¥··1116

Ill

. w Offices of J. Mark Moore Counsel for (j11i Twn Plaintiff

PEOPLE OF THE STATE OF CALIFORNIA

Kamala D. Harris Attorney General of the State of Califomfa

Dated: ----~2016 By:------------­

QUI ITAM PLAINTIFF

,2016

Approved as to Form:

Dated: ---"---·· --_,2016 By:------------­J. Mark Moore Law Offices of J. Mark Moore Counsel for Qui Tam Plaintiff

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K12 DEFENDANTS

Dated: __ 20 I 6 Jv5~15 ,,

Approved as to Form;

Dated: .2016 By: Timothy J. Hatch Gibson, Dunn & Crutcher LLP Counsel to K12 Inc.

Dated: ·----·-' 2016 By: r"'.e-,e-,"w=-a'"ld-:------------

Latham & Watkins LLP Counsel to Kl2 Inc.

CAVA DEFENDANTS

Dated· _______,2016 By: c:;-:cc:c--~-------­CAV A @ Fresno

Dated: , 2016 By. CAVA @ Jamestown

Dated: , 2016 By: CAVA@Kings

Dated: , 2016 By: CAVA @ Los Angeles

Dated: , 2016 By: CAVA @Maricopa

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KI2 DEFE!\D.-\!\"TS

. 2tl I (1

!Jakd: . 2016

Datc,I· . 2() 1(1

C,\V..\ DEFEND,\:--;Ts

Da1,.-d: .:?016

]);1tnl: . 20 16

n,1tcd: . 2U I h

Dall'd. . 20 I (,

l);1ll.'d: . 20 I f1

!:; \': K12 Inc .

13\. -------'----'---.~·------­l'imothv .1. I latch (Jiho,un. !)unn & ('rutchc1· l J,r ( ounsd t(1 f( i1 Inc.

!3) ·. ~ Peter \\ 11ld ] .atharn & Wdtk.ins I! P Cou11scl t,.1 K\2 !11c.

By:

fl)' C\ VA (al. Jame5tO\Yn

lh· (',\ \' ;\ ((/, Kmgs

lh·: ----­Ci\ \'A ·1'/:' !.(1.~ .\ngclc:s

I}\: l"AVA ,.a: ,\faricor,1

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K12 DEFENDANTS

Dated: ----~' 2016

Approved as to Form:

Dated: _____, 2016

By:-------------­KI2 Inc.

By:-------------­Timothy J. Hatch Gibson, Dunn & Crutcher LLP Counsel to Kl2 Inc.

Dated:~' 2016

CAVA DEFENDANTS

Dated: _____,2016

Dated: , 2016

Dated: 2016

Dated: 2016

Dated: 2016

By: __::;____________

Peter Wald Latham & Watkins LLP Counsel to K12 Inc.

By:------------­CAVA @Fresno

By: CAVA @ Jamestown

By: CAVA@Kings

By: CAVA @ Los Angeles

By: CAVA @ Maricopa

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OEFE:'\D,\ '\:TS

D,11cJ: .:'_()] (1

\pprr'l\Cd ns to 1-orm

Dated . 21116

D,ncd. . .:'.U 16

Dated: :J, "l . ::'()] h

l)atc-d:

.. 2lll 6

. .:'.U It,

Tmw1hy J I L1Kh (i1hson l)unn & Cnitchcr LLP l'oun~scl to Kl2 Inc:

II\"' Peter \\'aid I ntha111 & \\"atkins LLP l'liu1bcl w K12 Inc

1,//#B, ~ l'1\ \",\ 'l/ Fr·c~no

H;,. cc,-cc-~~--------- ­C.-\ \':\ ,1 Jame~to\\11

'

DEFENDANTS

Dated: _____, 2016 By:------------- ­Kl2 Inc.

Approved as to Form:

Dated: _____,, 2016 By: Timothy J, Hatch Gibson, Dunn & Crutcher LLP Counsel to K 12 Inc.

Dated: -----~,2016 By: ------------- ­Peter Wald Latham & Watkins LLP Counsel to K12 [nc.

Dated: _____,2016 By: ------------- ­

CAVA@ Fresno

Dated: _____,2016 By:--------------- ­CAVA@Kings

Dated: _____, 2016 By: -,,--,---:,---------- ­CAVA @ Los Angeles

Dated: ----~ 2016 By: -::-,-;-;-c-=-c-:--c-------­CAVA @ Maricopa

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a: www:;w~ -

DEFE"!DANTS

Dated: -----~2016 By: ------------- ­Kl2 Inc.

Approved as to Fann:

Dated: ______,, 2016 By:------------- ­Timothy J. Hatch Gibson, Dunn & Crutcher LLP Counsel to K12 Inc.

Dated: ______,2016 By, ------------- ­Peter Wald Latham & Watkins LLP Counsel to Kl 2 Inc.

Dated: ______. 2016 By: -------------- ­CAVA@ Fresno

Dated: _____,,2016 By: -,-----,~--------- ­CAVA @ Jamestown

Dated: Jv~y 7!1:' ,2016 By: ~~ CVA@Kings

Dated: , 2016 By: --,-----,----------­CAVA @ Los Angeles

Dated: ______, 2016 By: -------------- ­

CAVA@ Maricopa

DEFENDANTS

Dated: . 2016 By:------------ ­Kl2 Inc.

Aprrovi.:d as 10 Form:

Dated: .2016 By:------------ ­Timothy J. I-latch Gibson, Dunn & Crutcher LLP Counsel to Kl2 Inc.

Dated: . 2016 By:------------- ­Peter Wald Latham & Watkins LLP Counsel to K 12 Inc.

Du1ed: . 2016 By:-------------- ­CAVA @l Fresno

Dated: . 2016 By: -c-~--cc--------- ­CAVA @ Jamestown

Dated: ____.2016 By:~-~---------- ­CAVA@Kings

Dated: 7/J ~-- .2016

Dated: • 2016 By: -::ccc-:c--cc-:-c-c--------- ­CA V /\ @ Maricopa

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DEFENDANTS

Dated: _____,, 2016

Approved as to Form:

By:------------­Kl2 Inc.

Dated: _____,, 2016 By:-------------­Timothy J. Hatch Gibson, Dunn & Crutcher LLP Counsel to KI2 Inc.

Dated: ----~2016 By: -------------­Peter Wald Latham & Watkins LLP Counsel to Kl2 Inc.

Dated: ----~,2016 By: ------------- ­CAYA@ Fresno

Dated; , 2016 By: CAVA @ Jamestown

Dated: , 2016 By: CAVA@Kings

Dated: , 2016 By:

CAVA @ Los Angeles

Dated J v\y Q}: ,20 I6 By: CAl1~1,Q_b:

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-----

Dated:-----' 2016

Dated: _____,2016

Dated: _____,2016

Dated: , 2016

Dated: _____,2016

Dated: ----~' 2016

Dated: ----~2016

Dated: _____, 2016

Approved as to Form:

Dated: ----~ 2016

By: ----~------­CAVA@ San Diego

By:---:::-:::,--,---,------­CA VA @ San Joaquin

By:---,,-,---:-:-------­CA VA @ San Mateo

By: ------------­CAVA@ Sonoma

By: ---,----------­CAVA@ Sutter

By: ---c---:---,-------­Insight@ San Joaquin

By: ---:--:--=:------- ­Insight @ San Diego

By: -c--c--:---::--,--,-----­iQ Academy - Los Angeles

By: ,,.,----,,..,,----::-=---::------­young, Minney & Corr LLP Counsel to California Virtual Academies, Insight@ San Joaquin, Insight @ San Diego, iQ Academy - Los Angeles

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Dated: .2016 By: CAVA High School @ Maricopa

Dated: , 2016 7/7I

By: (fa/I~­C~Diego

Dated: . 2016 By: Ci\VA@ San Joaquin

Dated: .2016 By: CAVA@ San Mateo

Dated: , 2016 By: CAVA@ Sonoma

Dated: ,2016 By: CAVA @ Sutter

Dated: , 2016 Ry: Insight@ San Joaquin

Dated: , 2016 By: Insight @ San Diego

Dated: , 2016 By: iQ Academy - Los Angeles

Approved as to Form:

Dated: . 2016 By: Young, Minney & Con LLP Counsel to California Virtual Academies, Insight @ San Joaquin, Insight @ San Diego, iQ Academy - Los Angeles

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Dated: ,2016 By: CAVA High School @ Maricopa

Dated: ,2016 By: CAVA @San Diego

Dated: 7- 7- lk , 2016 By: ~d CAVA @San Joaquin

Dated: , 2016 By: CAVA @ San Mateo

Dated: , 2016 By: CAVA @ Sonoma

Dated: ,2016 By: CAVA @Sutter

Dated: ,2016 By: Insight@ San Joaquin

Dated: , 2016 By: Insight@ San Diego

Dated: , 2016 By: iQ Academy - Los Angeles

Approved as to Fonn:

Dated: ,2016 By: Young, Minney & Corr LLP Counsel to California Virtual Academies, Insight@ San Joaquin, Insight@ San Diego, iQ Academy - Los Angeles

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Dated: , 2016 By: CA VA High School@ Maricopa

Dated: , 2016 By: CAVA @ San Diego

Dated: ,2016 By: CAVA @ San Joaquin

Dated: 7/7/16 , 2016 By: CAVAQ~1

Dated: ,2016 By: CA VA @Sonoma

Dated: , 2016 By: CAVA@ Sutter

Dated: ,2016 By: Insight@ San Joaquin

Dated: , 2016 By: Insight@ San Diego

Dated: ,2016 By: iQ Academy - Los Angeles

Approved as to Form:

Dated: , 2016 By: Young, Minney & Corr LLP Counsel to California Virtual Academies, Insight@ San Joaquin, Insight@ San Diego, iQ Academy - Los Angeles

9

----------------

Datcd· . 20 16~---·----­ By (',,\ V.\ High School d i\iaricopa

Dated . 2016 11v · C.\ V:\ :'a San Dicgn

DatL'd. . 2() 16 -·-·------- fly: CAVA 'ci San J011quin

DateJ: . 2016 n~..

Dated: ____ ~-·-:1. 20 l 6

Dated: ____ .2016 Ry: -----------------­CAVA it Sultcr

Dated: Fl\': -----------------­Insight i'ii! San foaquin

Dated: ------· 2016 B, --------------­Insight r(i San 01cg0

Dated: ______. 2016 R'.: ---------------­

iQ Acadcm)· - Los Angeles

!\ppro\'cd as to Form:

Date(} _2016 [1~ .

YoII ng. :vlinney & Corr LI P Counsel to Cnlifornia Virtual ,\endemics. Insight ,l_t San Joaquin. [n:-.ight ·d San Dic120. iQ .'\cadt::my - Los Angeles ~

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Dated: _____, 2016 By: ______~-----­CA VA High School @ Maricopa

Dated; ___ ,2016 By:-------------­CAVA@ San Diego

Dated: _____, 2016 By: ==~~~-,-----­CAVA @ San Joaquin

Dated: _____ , 2016 By: ~=~~~,-------­CAVA @ San Mateo

Dated: ·-----' 2016 By· ~=c-c:'~-------­CAVA@ Sonoma

/'

Dated: .coc,;~I-D-7___, 2016 By: 4'£-'J/Zc__;c"~z:;L./'-----­CAVA ~tcr

Dated: _____, 2016 By:~~~~~-~------­Insight@ San Joaquin

Dated: ______, 20 l 6 By:-------------­Insight@ San Diego

Dated: ______, 2016 By:-------------­iQ Academy - Los Angeles

Approved as to Form:

Dated: _____ , 2016 By:~--~---------­Young, Minney & Corr LLP Counsel to California Virtual Academies, Insight@ San Joaquin, lnsight@San Diego, iQ Academy - Los Angeles

9

1 YMC LLC 9258489254 pageJul 08 2018 5:01AM

Dated: 2016 By: CAVA High School @Maricopa

Dated; ,2016 By: CAVA@ San Diego

Dated: 2016 By: CAVA @ San Joaquin

Dated: 2016 By: CAVA @ San Mateo

Dated: , 2016 By: CAVA @ Sonoma

Dated: , 2016 By: CAVA @ Sutter

Dated: 2016 By: Insight@ San Joaquin

Dated: , 2016 By: Insight@ San Diego

Dated: 2016 By: iQ Academy - Los Angeles

Approvrto Form:

Dated\.)_tJ~t Y , 2016 By: oun , Minney & Corr L

unset to California Virtu I Academies, Insight @ San Joaquin, Insight@ San Diego, iQ Academy- Los Angeles

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Dated: -----~· 2016 By: ~=~-~~-------­CAVA @ San Mateo

Daied: _____,,2016 By:--~---------­CAVA @ Sonoma

_____,, 2016 By:Dated: CAVA@Sutter

Dated: _____,,2016 By: --c-~cz-=--,-,-==-----­Insight@ San Joaquin

Dated: ----~2016 By: ~~=-=---==------­Insight@ San Diego

Dated:-~~ ,2016 By~()_~~Academy- Los Angeles

Approved as to Form:

Dated: --~2016 By: -,.,.---,-,=-----,,--,,,-,-,-,,------ ­young, Minney & Corr LLP Counsel to California Virtual Academies, Insight@ San Joaquin, Insight@ San Diego, iQ Academy - Los Angeles

THE STATE OF CALIFORNIA

Kamala D. Harris Attorney General ofthe State ofCaHfomia

Dated: ----~ 2016 By: -------------­

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Stipulation for Entry ofFinal Judgment

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Dated: _____, 2016 By: ==-=~-=--,....,------ ­CAVA @ San Mateo

Dated: _____, 2016

By:--~-~--------­insight@ San Diego

Dated: 07 / 07 , 2016 '

, Dated: (~7/1?8 , 2016

I

Dated: ______,, 2016

Dated: _____,, 2016

Approved as to Form:

By: --csc-c--,--~-,----.------- ­iQ Academy- Los Angeles

Dated: -----~,2016 By:=----~-------­Young, Minney & Corr LLP Counsel to California Virtual Academies, Insight@ San Joaquin, Insight (al San Diego, iQ Academy- Los Angeles ~

THE STATE OF CALIFORNIA

Kamala D. Harris Attorney General of the State ofCalifornia

Dated: _____,,2016 By:

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Stipulation for Entry of Pinal Judgment

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20

25

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

[lated: ____ , 2016 By: ------------- ­CAVA @ San Mateo

[lated: -----~2016 By: -------------- ­CAVA @ Sonoma

Dated: ____,2016 By:------------ ­CAVA@Sutter

[lated: _____, 2016 By:------------ ­Insight @ San Joaquin

[lated: _,__7/L'Y:::___, 2016 I

By: __oJ,~-'-/,,,,,J.~.::=---­ln~[)iego

Dated;,_·_____,2016

Approved as to Form:

By:-------------- ­iQ Academy-Los Angeles

Dated: _____,2016 By:~-------=----­Young, Minney & Corr LLP Counsel to California Virtual Academies, Insight@ San Joaquin, Insight@ San Diego, iQ Academy - Los Angeles

THE STATE OF CALIFORNIA

Kamala D. Harris Attorney General of the State of California

[lated: _____,2016 By: ------------- ­

5

Stipulation for Entry of Final Judgment