SETTLEMENT
On this 24th day of August 2022, a legally binding agreement By and Between
Plaintiff(s) Yassen28; Soukablet; and JamesGardai (“Plaintiffs”), AND Mr. Bohbazinga in his
official capacity as Adjutant General of the National Guard, on behalf of the National Guard, and
in his individual capacity where applicable (“Defendant”).
1. Definitions: the following definitions shall apply when used in this contract:
a. “Class of 013” shall mean the application cycle admitted on August 12th, 2022
into the Ridgeway National Guard in which Mr. Yassen28 would have been a part
of the Ridgeway National Guard’s background check denial.
b. At all times, this contract shall refer to the claims and factual allegations found in
Yassen28 v. National Guard, et al., RSC-AD-619 (2022).
c. “Ridgeway National Guard” shall be construed to mean all Defendants named in
the above entitled suit.
2. Agreements: the parties upon the signing of this document legally agree on the following
terms and conditions:
a. The Ridgeway National Guard will approve the Plaintiff’s background checks and
give them employment in the Ridgeway National Guard at the same rank,
pay-grade, and standing as those accepted in Class 013 on August 12, 2022.
b. The Ridgeway National Guard will do a comprehensive review of all documents
relating to the following: Alternative Account Detection, Background Check
Standards, or any other directive relating to the hiring process. Furthermore, will
update the documents accordingly to follow in-line with the Administrative
Procedures Act.
c. Bohbazinga, in his quasi-official capacity, will pay all attorney fees and filing
costs of the suit, totalling $1,735. A comprehensive breakdown will be as follows:
i. $100 flat fee for case filing, $125 in-game filing fee, $10 service fee,
$1,500 for 5 billable hours of service at a rate of $300 per hour.
d. The Ridgeway National Guard agrees to one month of no at will terminations of
the Plaintiffs in the aforementioned suit. Plaintiffs can not be fired at will for one
month after employment and finalization of this document.
e. Upon completion of all terms stated herein, the Plaintiff’s will drop all civil
claims associated with Yassen28 v. National Guard, et al., RSC-AD-619 and agree
that he will not pursue any further civil litigation related to the factual allegations
thereof against the Ridgeway National Guard except where provided by this
contract.
3. Termination of Agreement
a. If any party is found to have violated any clause, sentence or agreement within
this settlement they agree they are liable for civil damages in civil court for
violation of this contract.
b. If the Ridgeway National Guard violates this agreement, then they agree that they
are liable to all of the claims made in Yassen28 v. National Guard, et al.,
RSC-AD-619. They further agree to waive any privilege as it relates to discovery
requests regarding the litigation in the event that it re-opens in accordance with
this contract. They further agree to pay the costs of attorney and filing fees upon
the disposition of the case as assessed and normally charged by the Plaintiff.
/s/ Bohbazgina
Bohbazgina on behalf of the
State of Ridgeway and the
National Guard in his official
capacity as Adjutant General.
Defendant
/s/RyanJSyndicate
RyanJSyndicate, in his official
Capacity as Associate Solicitor
General acting under the
Authority of the Solicitor
General’s Office for the State.
Counsel for Defendant
/s/ stickza
Stickza
Counsel of Record
/s/ JamesGardai
JamesGardai
Plaintiff
/s/ Soukablet
Soukablet
Plaintiff
/s/ Yassen28
Yassen28
Plaintiff
Dated August 24, 2021