CONFIDENTIAL SETTLEMENT AND GENERAL RELEASE AGREEMENT 

This Confidential Settlement and General Release Agreement ("AGREEMENT") is 

entered into by and between WALTER KROLL ("KROLL") and KVZ GOLF, LLC d/b/a Palm 

Cove Golf and Yacht Club ("KVZ GOLF") (collectively referred to as the "Parties"). The 

individual(s) executing this Agreement on behalf of Defendant has all requisite capacity, power 

and authority to bind Defendant to this Agreement, and to perform all obligations hereunder. 

RECITALS 

This AGREEMENT is made with reference to the following facts: 

A. WHEREAS, KROLL filed an action against KVZ GOLF entitled Walter Kroll v. 

KVZ GOLF, LLC cl/b/a Palm Cove Golf and Yacht Club, CASE NO. 20-cv-14150- 

MAYNARD in the United States District Court of the Southern District of Florida 

in Miami, Florida (the "ACTION"); and 

B. WHEREAS, KVZ GOLF denies the validity of KROLL'S claims and denies that 

it is subject to any liability; and 

C. WHEREAS, all Parties wish to settle their differences without resort to further 

litigation; and 

D. WHEREAS, KVZ GOLF is willing to provide KROLL with certain consideration 

described below, which it is not ordinarily required to, provided KROLL releases 

KVZ GOLF from any and all claims arising out of the ACTION and his 

employment with KVZ GOLF, and agrees to comply with the other promises and 

conditions set forth in this AGREEMENT; and 

NOW THEREFORE, in consideration of the mutual covenants and promises contained 

herein, and other good and valuable consideration, the receipt and sufficiency of which are hereby 

acknowledged by the Parties, the Parties agree to be legally bound by the following terms and 

conditions, which constitute full settlement of any and all disputes between them: 

I. Recitals: The Parties acknowledge that the "WHEREAS" clauses preceding 

paragraph I are true and correct, and are incorporated herein as material parts to 

this AGREEMENT. 

2. Definitions: Throughout this AGREEMENT, the term "KVZ GOLF" shall include 

the following: 

(A) KVZ GOLF, LLC d/b/a Palm Cove Golf and Yacht Club, its past, present 

and future parent companies, holding companies, subsidiaries, affiliates, 

and each of their officers, directors, stockholders, owners (including but not 

limited to Miroslav Vojtisek), members, managers, employees, agents, 

investors, representatives (collectively referred to as the "Released 

Parties"); and 

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(B) Any officer, director, trustee, attorney, agent, employee, or insurer of an 

entity encompassed by subparagraph (A). 

3. Settlement Sum: As consideration for signing this AGREEMENT and compliance 

with the promises made herein, KVZ GOLF agrees to pay KROLL the gross sum 

of TWENTY-SIX THOUSAND FIVE HUNDRED DOLLARS AND 001100 

CENTS ($26,500.00) (the "Settlement Sum"), which shall be allocated as follows: 

(A) Eight Thousand Dollars and 00/100 Cents ($8,000.00), less applicable 

withholdings, made payable to WALTER KROLL as full and final 

settlement for his claims for unpaid wages pursuant to the FLSA and 

Minimum Wage Act for which a W-2 will be issued; 

(B) Eight Thousand Dollars and 00/100 Cents ($8,000.00) made payable to 

WALTER KROLL as full and final settlement for his claims for liquidated 

damages pursuant to the FLSA for which a 1099 will be issued; and 

(C) Ten Thousand Five Hundred Dollars and 00/100 Cents ($10,500.00) made 

payable to Robert S. Norell, P.A. for all fees and costs incurred in 

connection with the ACTION for which amount a Form 1099 will be 

provided to KROLL and his attorneys. 

The Parties stipulate that the Settlement Sum, including the attorney's fees paid as 

part thereof, is a fair and reasonable settlement of KROLL's FLSA and minimum 

wage claims. KVZ GOLF shall provide the consideration identified in this 

paragraph 3 to KROLL at the address set forth in Paragraph 20 no later than ten 

(10) days after satisfaction of all of the following conditions precedent: 

(I) receipt by counsel for KVZ GOLF of this AGREEMENT appropriately handsigned and dated by KROLL; 

(2) receipt by counsel for KVZ GOLF of IRS Form W-4 fully executed by KROLL 

and IRS Forms W-9 fully executed by both KROLL and his counsel; 

(3) expiration of the Review/Revocation Period in Paragraph No. 23 without 

KROLL having exercised any revocation rights; and 

(4) entry in the ACTION of an Order approving of the settlement terms set forth in 

this AGREEMENT to provide for the dismissal of the ACTION with each party to 

bear its own legal fees and costs following payment of the consideration set forth 

herein. The Parties agree that they and their respective counsel shall cooperate and 

execute such other documents or pleadings as may be necessary for the approval of 

this Agreement and the dismissal with prejudice of the Lawsuit. 

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This AGREEMENT shall not become effective, therefore, and none of the benefits 

set forth in this paragraph will become due or payable, until after the Effective Date 

of this AGREEMENT (the "Effective Date" defined as the first day after KVZ 

GOLF has received all of the items described in this paragraph),, 

4. Consideration: KROLL understands and agrees that he would not receive all of 

the monies and/or benefits specified in paragraph 3 above, but for his execution of 

this AGREEMENT and the fulfillment of the promises contained herein. KROLL 

agrees that this Agreement constitutes a full and complete settlement of his claims. 

KROLL further agrees that he will not seek any further compensation for any other 

claimed damage, costs, or attorneys' fees in connection with the ACTION 

encompassed in this AGREEMENT. 

5. General Release of Claims: In exchange for, and in consideration of, the 

payments, benefits, and other commitments described above, KROLL, for himself 

and for each of his heirs, executors, administrators, and assigns, hereby fully 

releases, acquits, and forever discharges KVZ GOLF, and each of its predecessors, 

successors and assigns, parent corporations, subsidiary corporations, affiliated 

corporations, and the officers, directors, shareholders, partners, employees, 

attorneys and agents, past and present, of each of the aforesaid entities ("Related 

Persons") of and from any and all claims, liabilities, causes of action, demands to 

any rights, damages, costs, attorneys' fees, expenses, and compensation 

whatsoever, of whatever kind or nature, in law, equity or otherwise, whether known 

or unknown, vested or contingent, suspected or unsuspected, that KROLL may now 

have, has ever had, or hereafter may have relating directly or indirectly to his 

provision of services to and alleged employment with KVZ GOLF, including, but 

not limited to, claims for wages; back pay; front pay; reinstatement; damages; 

attorneys' fees; or benefits. KROLL also releases any and all claims he may have 

that arose prior to the date of this AGREEMENT, and hereby specifically waives 

and releases all claims, including, but not limited to, those arising under Florida 

Statute Section 440.205, Title VII of the Civil Rights Act of 1964; the Civil Rights 

Act of 1991; the Americans with Disabilities Act of 1990; the Age Discrimination 

in Employment Act, as amended (ADEA); the Rehabilitation Act of 1973; Florida's 

minimum and unpaid wage laws; Sections 1981 through 1988 of Title 42 of the 

United States Code; the Immigration Reform and Control Act; the Workers 

Adjustment and Retraining Notification Act; the Occupational Safety and Health 

Act; the Family and Medical Leave Act; the Sarbanes-Oxley Act of 2002; the 

Consolidated Omnibus Budget Reconciliation Act (COBRA); the Employee 

Retirement Income Security Act of 1974; The Fair Labor Standards Act; the Age 

Discrimination in Employment Act; the National Labor Relations Act; the Florida 

Civil Rights Act of 1992; and any and all state or local statutes, ordinances, or 

regulations, as well as all claims arising under federal, state, or local law involving 

any tort, employment contract (express or implied), public policy, wrongful 

discharge, or any other claim. KROLL also releases all claims made and all claims 

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that could have been made in the ACTION, and hereby specifically releases said 

claims. 

This AGREEMENT shall not apply to rights or claims that may arise after the 

Effective Date of this AGREEMENT. Nothing in this paragraph or this 

AGREEMENT is intended to limit or restrict any rights KROLL may have to 

enforce this AGREEMENT, or any other rights that cannot, by express and 

unequivocal terms of law, be limited, waived, or extinguished. KROLL agrees and 

covenants not to file any suit, charge, or complaint against KVZ GOLF in any court 

or administrative agency, with regard to the matters encompassed by this 

AGREEMENT. KROLL further represents that, with the exception of the Action 

described in the Recitals' subparagraph (A), no claims, complaints, charges, or 

other proceedings are pending in any court, administrative agency, commission or 

other forum relating directly or indirectly to KROLL's provision of services to and 

alleged employment with, or separation from, KVZ GOLF. Nothing in this 

Agreement shall be construed to prohibit KROLL from filing a charge with the 

Equal Employment Opportunity Commission ("Commission"), National Labor 

Relations Board ("NLRB") or any other federal, state, or local agency or 

participating in any investigation or proceeding conducted by such administrative 

agencies or from exercising rights under Section 7 of the NLRA to engage in joint 

activity with other employees, although by signing this Agreement KROLL is 

waiving rights to individual relief based on claims asserted in such a charge or 

complaint, except where such waiver of individual relief is prohibited. 

6. Tax Liability; KROLL understands that KVZ GOLF shall issue an IRS Form 1099 

to KROLL and his legal counsel for those portions of the payment specified in 

paragraph 3 of this AGREEMENT. In paying the amount specified in paragraph 

3, KVZ GOLF makes no representation regarding the tax consequences subject to 

the issuance of a Form 1099 or liability arising from said payment. KROLL 

understands and agrees that any and all tax liability that may be due or become due 

because of the payment subject to the issuance of a Form 1099 is his sole 

responsibility, and that he will pay any such taxes that may be due or become due. 

KVZ GOLF has no monetary liability or obligation regarding the payment subject 

to the issuance of Form 1099 whatsoever. KROLL agrees to bear all tax 

consequences, if any, attendant upon the payment to them of the sums subject to 

the issuance of Form 1099 KROLL further agrees to hold KVZ GOLF harmless 

from and against any tax or tax withholdings claims, amounts, interest, penalties, 

fines, or assessments brought or sought by any taxing authority or governmental 

agency with regard to the sums subject to the issuance of Form 1099. 

7. Affirmations:KROLL represents and affirms that, other than the instant 

proceeding, he has no suits, claims, charges, complaints or demands of any kind 

whatsoever currently pending against KVZ GOLF with any local, state, or federal 

court or any governmental, administrative, investigative, civil rights or other 

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agency or board. KROLL further represents and affirms that he has been paid 

and/or received all leave (paid or unpaid), compensation, wages, bonuses, 

commissions, and/or benefits to which he may be entitled and that no other leave 

(paid or unpaid), compensation, wages, bonuses, commissions, and/or benefits are 

due him, except as provided for in this AGREEMENT. 

8. No Employment: KROLL permanently, unequivocally and unconditionally 

waives any and all rights KROLL may have, may have had in the past, or may have 

in the future to obtain employment with KVZ GOLF or resume providing any 

services on its property. KROLL further agrees never to apply for employment with 

KVZ GOLF, its parent, successors, affiliated companies and/or subsidiaries. In the 

event that Kroll is ever mistakenly employed by KVZ GOLF, its parent, successors, 

affiliates, and/or subsidiaries, KROLL agrees to have his employment terminated 

with no resulting claim or cause of action against the Related Persons. 

9. No Assignment:The Parties represent and warrant that no person other than the 

signatories hereto had or has any interest in the matters referred to in this 

AGREEMENT, that the Parties have the sole right and exclusive authority to 

execute this AGREEMENT, and that the Parties have not sold, assigned, 

transferred, conveyed, or otherwise disposed of any claim, demand or legal right 

that is the subject of this AGREEMENT. 

10. KROLL'S Non-Disclosure and Non-Disparagement Obligations: 

(A) In consideration of KVZ GOLF's obligations under this AGREEMENT, 

KROLL agrees that that neither KROLL nor his heirs, agents, executors, 

administrators, attorneys, legal representatives or assigns shall disclose or 

disseminate, directly or indirectly, any information concerning any terms of 

this AGREEMENT to any third person(s), including, but not limited to, 

representatives of the media or other present or former associates of KVZ 

GOLF, under any circumstances, except KROLL may disclose the terms of 

this AGREEMENT to his attorney, accountant, tax advisor, the Internal 

Revenue Service, or as otherwise required by law ("Third Parties"); 

provided, however, that the Third Parties to whom such disclosure is made 

shall agree in advance to be bound by the terms of this paragraph 10 and all 

of its subparts. 

(B) KROLL agrees that, in all future communications and interactions with any 

and all third parties in any public or private forum, he will not provide 

information, issue statements, take any action, directly or indirectly, 

expressly or impliedly, anonymously or pseudonymously, regarding KVZ 

GOLF in a detrimental, derogatory or disparaging manner. For purposes of 

this Section, "detrimental, derogatory or disparaging" shall mean any 

negative or critical statement, whether written or oral in any form of 

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communication, forum or media format whatsoever, that could be harmful 

to or reflect negatively on KVZ GOLF, its officers, directors or employees 

(and/or any of the Released Parties) or that could otherwise be harmful or 

reflect negatively on any of their business or personal reputations or 

goodwill. This restriction includes, but is not limited to, social media 

postings such as on Facebook, Instagram or Linkedln. 

(C) KROLL will not voluntarily aid or assist, either directly or indirectly, any 

individual or entity in the assertion or pursuit of any private claim or the 

prosecution of any private lawsuit, action, arbitration or judicial or 

administrative proceeding now existing or hereinafter arising against the 

Released Parties.. Nothing contained in this Paragraph shall be construed to 

limit the rights provided in Paragraph 22 of this AGREEMENT or 

Plaintiff's obligation to respond to any requests in the form of a valid 

subpoena, deposition notice, court order or similar judicial, administrative, 

governmental or regulatory request, which requires Plaintiff to appear at 

trial, deposition or a court or administrative hearing to give truthful 

testimony. Plaintiff agrees, however, that if he receives any subpoena, 

deposition notice, court order and/or other formal request for testimony, he 

will immediately inform KVZ GOLF in writing in accordance with the 

Notice provisions set forth in Paragraph 20. 

(D) KROLL acknowledges that a violation of paragraph 10 or any of its subparts 

would cause immeasurable and irreparable damage to KVZ GOLF in an 

amount incapable of precise determination. Accordingly, KROLL agrees 

that KVZ GOLF shall be entitled to injunctive relief in any court of 

competent jurisdiction for any actual or threatened violation of paragraph 

10 and all of its subparts, in addition to any other available remedies. 

11. KVZ Golf's Non-Disparagement Obligations: KVZ GOLF will instruct 

Miroslav Vojtisek not to speak about this matter or disparage KROLL and to 

maintain as confidential the terms of this Agreement, except when speaking with 

KVZ GOLF's attorneys, tax consultants, and financial advisors, as necessary to 

effectuate the terms of this Agreement, and in connection with reasonable business 

purposes, unless otherwise directed to do so by a Court of law or other regulatory 

body, to respond to a subpoena, or as otherwise required by any law, rule or 

regulation of any governmental agency or regulatory authority. Vojtisek agrees 

that, in all future communications and interactions with any and all third parties in 

any public or private forum, he will not provide information, issue statements, take 

any action, directly or indirectly, expressly or impliedly, anonymously or 

pseudonymously, regarding KROLL in a detrimental, derogatory or disparaging 

manner. For purposes of this Section, "detrimental, derogatory or disparaging" 

shall mean any negative or critical statement, whether written or oral in any form 

of communication, forum or media format whatsoever, that could be harmful to or 

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reflect negatively on KROLL, or that could otherwise be harmful or reflect 

negatively on any of his business or personal reputations or goodwill. This 

restriction includes, but is not limited to, social media postings such as on 

Facebook, Instagram or LinkedIn. 

KVZ GOLF shall provide a neutral verification of KROLL's provision of services 

to and alleged employment with KVZ GOLF to any prospective employer and such 

reference shall be limited to KROLL's job title and dates of services. In connection 

therewith, KROLL agrees that he will refer any prospective employer or other third 

party to contact Miroslav Vojtisek at mirekv@earthlink.net to verify Employee's 

employment. Should KROLL fail to use this sole method to obtain employment 

verification, KVZ GOLF makes no guarantees of any neutral employment 

reference and KROLL waives any right to bring a claim against KVZ GOLF 

relating to the content of such reference if he uses any other or additional means for 

employment verification. 

12. Governing Law and Jurisdiction: This AGREEMENT shall be governed and 

conformed in accordance with the laws of the state of Florida without regard to its 

conflict of laws provision. Further, the Parties agree that federal and state courts in 

Martin County shall have personal jurisdiction over him with regards to any action 

brought to enforce this AGREEMENT. In the event either party breaches any 

provision of this AGREEMENT, each party affirms that either party may institute 

an action to specifically enforce any term or terms of this AGREEMENT. The 

Parties agree that the state courts of Florida shall have continuing jurisdiction over 

the instant action for ninety (90) days following the dismissal of the action. 

13. Conditions: Should one party ever breach any provision or material obligation 

under this AGREEMENT, upon a proven breach that party explicitly agrees to pay 

all damages (including, but not limited to, litigation and/or defense costs, expenses, 

and reasonable attorney's fees) incurred by the non-breaching party as a result of 

the breach. Nothing in this paragraph shall, or is intended to, limit or restrict any 

other rights or remedies the Parties may have by virtue of this AGREEMENT or 

otherwise. 

14. No Admission of Liability or Retracting of Claims Made: The Parties agree that 

neither this AGREEMENT nor the furnishing of the consideration for this 

AGREEMENT shall be deemed or construed at any time for any purpose as an 

admission by KVZ GOLF of any liability or unlawful conduct of any kind in this 

or any other proceeding, nor shall it be deemed a retractment of the claims made by 

KROLL. 

15. Headings: The headings of the provisions herein are intended for convenient 

reference only, and the same shall not be, nor be deemed to be, interpretive of the 

contents of such provision. 

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16. Modification of Agreement: This AGREEMENT may not be amended, revoked, 

changed, or modified in any way, except in writing executed by all Parties. The 

Parties agree not to make any claim at any time or place that this AGREEMENT 

has been verbally modified in any respect whatsoever. No waiver of any provision 

of this AGREEMENT will be valid unless it is in writing and signed by the party 

against whom such waiver is charged, The Parties acknowledge that only Miroslav 

Vojtisek has the authority to modify this AGREEMENT on behalf of KVZ GOLF. 

17. Interpretation: The language of all parts of this AGREEMENT shall in all cases 

be construed as a whole, according to its fair meaning, and not strictly for or against 

any of the Parties. This AGREEMENT has been negotiated by and between the 

Parties and shall not be construed against the "drafter" of the AGREEMENT. If 

any portion or provision of this AGREEMENT (including, without implication of 

limitation, any portion or provision of any section of this AGREEMENT) is 

determined to be illegal, invalid, or unenforceable by any court of competent 

jurisdiction and cannot be modified to be legal, valid, or enforceable, the remainder 

of this AGREEMENT shall not be affected by such determination and shall be valid 

and enforceable to the fullest extent permitted by law, and said illegal, invalid, or 

unenforceable portion or provision shall be deemed not to be a part of this 

AGREEMENT. 

18. Binding Nature of Agreement: This AGREEMENT shall be binding upon each 

of the Parties and upon their respective heirs, administrators, representatives, 

executors, successors, and assigns, and shall inure to the benefit of each party and 

to their respective heirs, administrators, representatives, executors, successors, and 

assigns. 

19. Entire Agreement: This AGREEMENT sets forth the entire AGREEMENT 

between the parties hereto, and fully supersedes any prior obligation of KVZ GOLF 

to KROLL, and any prior confidentiality, non-solicitation, non-disparagement, jury 

waiver, arbitration, venue selection and choice of law provisions between the 

parties are excepted from this paragraph and shall survive this AGREEMENT. 

KROLL acknowledges that he has not relied on any representations, promises, or 

agreements of any kind made to him in connection with his decision to accept this 

AGREEMENT, except for those set forth in this AGREEMENT. 

20. Notice Requirements: Each notice ("Notice") provided for under this 

AGREEMENT, must comply with the requirements as set forth in this paragraph. 

Each Notice shall be in writing and sent by E-Mail addressed to the appropriate 

party (and marked to a particular individual's attention, if so indicated) as 

hereinafter provided. Each Notice shall be effective upon the date it is sent. Any 

party shall have the right from time to time to change the e-mail address or 

individual's attention to which notices to it shall be sent by giving to the other party 

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at least ten (10) days' prior Notice thereof. The Parties' addresses for providing 

Notices hereunder shall be as follows: 

KVZ GOLF LLC cl/b/a Palm Cove Golf and Yacht Club 

c/o Stefanie Mederos, Esq. 

Littler Mendelson, P.C. 

Wells Fargo Center 

333 SE 2nd Avenue, Suite 2700 

Miami, FL 33131 

E-mail Address: smederos(a,littler.com ; scolomboaitlitler.com 

WALTER KROLL 

c/o Robert Norell, Esq. 

Robert S. Norell, PA. 

300 N.W. 70th Avenue, Suite 305 

Plantation, Florida 33317 

E-mail Address: rob@floridawagelaw.com ; assistantra)floridawaRelaw.com 

21. Selective Enforcement: The Parties agree that the failure of any party to enforce 

or exercise any right, condition, term, or provision of this AGREEMENT shall not 

be construed as or deemed a relinquishment or waiver thereof, and the same shall 

continue in full force and effect. 

22. Right to Engage in Protected Activity: Nothing in this AGREEMENT 

including but not limited to the General Release of Claims, No Further 

Employment, Non-Disclosure, Non-Disparagement, Conditions Paragraphs, 

or any other Paragraphs whether referencing this Paragraph or not, prevents 

ICROLL from filing a charge or complaint with, from participating in an 

investigation or proceeding conducted by, providing information to, or 

otherwise assisting the EEOC, NLRB, SEC, or any other federal, state or local 

agency charged with the enforcement of any laws, or from exercising rights 

under Section 7 of the NLRA to engage in joint activity with other employees, 

although by signing this AGREEMENT KROLL is waiving rights to 

individual relief (including front pay, back pay, reinstatement or other legal 

or equitable relief) based on claims asserted in such a charge or complaint or 

other proceeding brought by ICROLL or on his behalf by any third party, 

except for any right ICROLL may have to receive a payment from a 

government agency (and not the Company) for information provided to the 

government agency or otherwise prohibited. 

22. Sienatures in Counterparts: This AGREEMENT may be executed in 

counterparts, and each counterpart, when executed, shall have the efficacy of a 

signed original. Such counterparts shall together constitute one and the same 

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document. The Parties agree that facsimile and/or scanned signatures shall be 

treated as original signatures. 

23. Corn i 'lance with Older Workers Benefit Protection Act: KROLL, being 40 

years of age or older and having the intent to release any claims under the Age 

Discrimination in Employment Act as set forth in Paragraph 5, is advised of and 

acknowledges the following: 

(A) Twenty-One Day Consideration Period. KROLL shall have up to twenty-one (21) 

days to consider and accept the terms of this Agreement by fully executing and 

notarizing it below, and returning it to KVZ GOLF, as identified in Paragraph No. 

20. During this twenty-one (21) day period arid before signing this Agreement, 

KROLL is encouraged to consult with an attorney regarding the terms and 

provisions of this Agreement, at his own expense. The terms and provisions of this 

Agreement are null and void if not accepted by KROLL within the twenty-one (21) 

day period. KROLL may sign the Agreement prior to the conclusion of the twentyone (21) day period. 

( 3) Release of Age Discrimination in Employment Act Claims. By signing this 

Agreement, KROLL waives any claims he has or might have against KVZ GOLF 

under the Age Discrimination in Employment Act ("ADEA") that accrued prior to 

the date of KROLL'S execution of the Agreement. 

(C) Revocation Period. KROLL shall have seven (7) calendar days from the date he 

signs this Agreement to revoke the Agreement by notifying KVZ GOLF in writing 

prior to the expiration of the seven (7) calendar day period. Any revocation within 

this period must state, "I hereby revoke my acceptance of our Agreement and 

General Release." The written revocation must be sent to KVZ GOLF in the 

manner proscribed by Paragraph No. 20 above and by depositing it with a nationally 

recognized overnight courier service that obtains receipts (such as Federal Express 

or UPS Next Day Air) addressed to the appropriate party (and marked to a particular 

individual's attention, if so indicated) to the address set forth in Paragraph No. 20, 

and must be sent within seven (7) calendar days of KROLL's execution of this 

Agreement. This Agreement shall not become effective or enforceable until the 

revocation period has expired. If the last day of the revocation period is a Saturday, 

Sunday, or legal holiday, then the revocation period shall not expire until the next 

following day that is not a Saturday, Sunday, or legal holiday. 

KROLL IS HEREBY ADVISED THAT HE HAS UP TO TWENTY-ONE (21) CALENDAR 

DAYS TO REVIEW AND CONSIDER THIS AGREEMENT AND IS HEREBY ADVISED 

IN WRITING TO CONSULT WITH AN ATTORNEY PRIOR TO EXECUTION OF THIS 

AGREEMENT. 

ICROLL AGREES THAT ANY MODIFICATIONS, MATERIAL OR OTHERWISE, 

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WALTER KROLL 

KROLL v. KVZ GOLF, LLC 

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MADE TO THIS AGREEMENT DO NOT RESTART OR AFFECT IN ANY MANNER 

THE ORIGINAL TWENTY-ONE (21) CALENDAR DAY CONSIDERATION PERIOD. 

HAVING ELECTED TO EXECUTE THIS AGREEMENT, TO FULFILL THE 

PROMISES AND TO RECEIVE THE SUMS AND BENEFITS IN PARAGRAPH 3 

ABOVE, ICROLL FREELY AND KNOWINGLY, AND AFTER DUE CONSIDERATION, 

ENTERS INTO THIS AGREEMENT INTENDING TO WAIVE, SETTLE, AND 

RELEASE ALL CLAIMS HE HAS OR MIGHT HAVE AGAINST KVZ GOLF. 

ACCEPTED AND AGREED: 

Dated: / 2-- 

Dated: KVZ GOLF LLC d/b/a Palm Cove Golf and Yacht 

Club 

By: 

Print Name: 

Title: 

11 

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KVZ GOLF LLC d/b/a Palm Cove Golf and Yacht 

Club 

By: 

KROLL v. KVZ GOLF, LW 

Page I 

MADE TO THIS AGREEMENT DO NOT RESTART OR AFFECT IN ANY MANNER 

THE ORIGINAL TWENTY-ONE (21) CALENDAR DAY CONSIDERATION PERIOD. 

HAVING ELECTED TO EXECUTE THIS AGREEMENT, TO FULFILL THE 

PROMISES AND TO RECEIVE THE SUMS AND BENEFITS IN PARAGRAPH 3 

ABOVE, KROLL FREELY AND KNOWINGLY, AND AFTER DUE CONSIDERATION, 

ENTERS INTO 'l'HIS AGREEMENT INTENDING TO WAIVE, SETTLE, AND 

RELEASE ALL CLAIMS HE HAS OR MIGHT HAVE AGAINST KVZ GOLF. 

ACCEPTED AND AGREED: 

Dated: 

WALTER ICROLL 

DatedA."2 

CliAor4.14V J,4 7T,/< 

Title: nvig_60)6 hen g6g--- 

Print Name: 

11 

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