STIPULATION
OF SETTLEMENT AGREEMENT


 


This
Settlement Agreement (“Agreement”) as of October 25, 2018 (“Effective Date”), is
entered into by and among Libertas Funding LLC located at 382 Greenwich Ave, Suite 2, Greenwich, CT 06830, and Kinetic
Direct Funders located at 382 Greenwich Ave, Suite 2, Greenwich, CT 06830 (hereinafter “Funders”) and the
following specific Merchants (hereinafter “Merchants”):


 


	 	a.	re:
    Judgement by Confession, Index No. 18814598, for the amount of $1,008,566.74


 


Naveen
Doki


4902
Finchen Cr


Manassas,
VA 20109


 


US
IT Solutions, Inc


3031
Tisch Way


110
Plaza West, Ste 1098 San Jose, CA 95128


 


360
IT Professionals Inc.


5201
Great America Pkw, Ste 256 Santa Clara. CA 95054


 


	 	b.	re:
    Judgement by Confession, Index No. 18814435, for the amount of $579,259.30 


 


Naveen
Doki


4902
Finchen Cr, Manassas, VA 20109


 


The
Maslow Media Group, Inc. US IT Solutions, Inc.


360
IT Professionals Alliance Micro, Inc.


all
located at: 2233 Wisconsin Ave NW, Ste 400, Washington, DC 20007


 


	 	c.	re:
    Judgement by Confession, Index No. 18814438, for the amount of $229,320.26 


 


Silvija
Valleru


6206
Colchester Rd, Fairfax, VA 22030


 


Alliance
Micro Inc.


Vivos
IT, LLC


Vivos
Global Services, LLC Vivos Holdings, LLC


Vivos
Acquisitions, LLC Maslow Media Group, Inc.


all
located at: 12154 Darnestown Rd, Gaithersburg, MD 20878


 




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	 	d.	re:
    Judgement by Confession, Index No. 18814597, for the amount of $229,320.26


 


Naveen
Doki





4902
Finchen Cr, Manassas, VA 20109


 


Alliance
Micro Inc. Vivos IT, LLC


Vivos
Global Services, LLC Vivos Holdings, LLC


Vivos
Acquisitions, LLC Maslow Media Group, Inc.


all
located at: 12154 Darnestown Rd, Gaithersburg, MD 20878


 


WHEREAS,
Funders purchased accounts receivables from Merchants,


 


WHEREAS,
Merchants sold said accounts receivables to Funders for good and valuable consideration both Funders and Merchants attest hereto,


 


WHEREAS,
Merchants failed to deliver the full amount of said accounts receivables to Funders,


 


WHEREAS,
Silvija Valleru and Naveen Doki personally guaranteed any monies owed to Funders,


 


WHEREAS,
Merchants acknowledge a failure to deliver receivables in the full amount owed to Funders.


 


NOW
THEREFORE, in consideration of the mutual covenants contained herein, and for good and valuable consideration, the receipt
and sufficiency of which is hereby acknowledged, the parties to this Agreement (collectively, the “Parties” and each
individually, a “Party”) agree as follows:


 


	 	1.	This
    Agreement is in the settlement of this matter only and only includes Merchants listed above as part of each individual Judgment
    By Confession (“COJ”), and shall not affect, alter or modify any claims, defenses or Judgments Funder has to any
    party, otherwise listed or not listed above, who is subject to one COJs listed as part of this Agreement.
	 	 	 
	 	2.	Due
    to the fact that Healthcare Resource Network, LLC (“HCRN”), a Defendant to COJs “b”, “c’,
    and “d” listed above, has currently commenced litigation regarding the validity of the COJs, as well as the agreements
    which spawned the COJs (“Litigation”), this Agreement shall not include HCRN, nor shall it remove, vacate, or
    affect any and all claims, defenses, personal guarantees and Judgments Funders have against HCRN, or Vivos Acquisitions, LLC
    in relation to its obligations due to HCRNs liability, or any other parties relating to HCRNs liability.


 


	 	a.	Unless
    Merchants are in default of this Agreement Funders shall not enforce any action against Silvija Valleru or Naveen Doki, specifically
    in relation to their Personal Guaranty of monies owed by HCRN or Vivos Acquisitions, LLC, until the Litigation is settled
    to which Funders are a party to.


 




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	 	b.	In
    addition, unless Merchants are in default of this Agreement, and it is determined that Naveen
    Doki, Silvija Valleru and Vivos Acquisitions, LLC were within their full rights as owners and representatives of HCRN when
    they entered into contracts with Funders, the Personal Guarantees obligating Naveen Doki and Silvija Valleru to Funders shall
    be waived. However, if it is determined that Naveen Doki, Silvija Valleru and Vivos Acquisitions, LLC did not have the legal
    authority to bind HCRN to Funders, then Naveen Doki and Silvija Valleru shall be personally liable and obligated for any monies
    not yet collected on the COJs.
	 	 	 
	 	c.	Merchants
    shall notify Funders within five (5) days of any final settlement agreements reached or court outcomes regarding the
    Litigation.
	 	 	 
	 	d.	This
    clause (“2.”) in whole, shall supersede any and all other clauses in this Agreement.


 


	 	3.	Merchants
    hereby agree to pay, and Funders agree to accept, in full satisfaction of Merchants debt, the sum of $750,000.00 (“settlement
    payment”) to be paid on or before as follows:


 


	October 31, 2018	 	$	42,500.00	 
	November 20, 2018	 	$	42,500.00	 
	December 31, 2018	 	$	55,363.48	 
	January 31, 2019	 	$	57,461.63	 
	February 28, 2019	 	$	59,769.59	 
	March 31, 2019	 	$	62,308.35	 
	April 30, 2019	 	$	65,100.99	 
	May 31, 2019	 	$	150,000.00	 
	June 30, 2019	 	$	68,172.89	 
	July 31, 2019	 	$	71,551.97	 
	August 31, 2019	 	$	75,271.10	 



 




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	 	4.	Funders
    shall release all UCCs held against Merchants upon the full and complete payment of the first two scheduled payments.
	 	 	 
	 	5.	This
    Agreement shall not prohibit Funders from Domesticating the COJs that are part of this Agreement. However, Funders shall not
    enforce said COJs unless Merchants default on this Agreement.
	 	 	 
	 	6.	Payments
    are to be made by check, money order (made payable to The Faskowitz Law Firm, PLLC and sent to The Faskowitz
    Law Firm, PLLC, 61-43 186 Street, Suite 207, Fresh Meadows, NY, 11365 with your file number on the check or money order),
    or wire (information upon request).
	 	 	 
	 	7.	Should
    any payment not be received by the due date, or should any check sent in payment be returned by the bank for any reason whatsoever
    and the payment not be received within five (5) days after written notification to Merchant, Funders shall have the
    right to enforce the COJs, without further notice, for the full COJ amounts, together with statutory interest, less any payments
    made.
	 	 	 
	 	8.	Merchants
    waive any and all defenses, jurisdictional or otherwise, in any action currently pending or to be commenced upon default to
    collect the debt herein or to enforce this Agreement.
	 	 	 
	 	9.	Upon
    full compliance with this Agreement, this matter shall be deemed fully satisfied between Funders and Merchants and no legal
    action shall be commenced.
	 	 	 
	 	10.	Facsimile
    signatures shall be deemed original for purposes of this settlement stipulation only.
	 	 	 
	 	11.	Mutual
    Release of Claims:


 


In
consideration of the Settlement Payment and subject to the terms and conditions set out in this Agreement, and other good and
valuable consideration, receipt of which is hereby acknowledged, Merchants their successors, assigns, estates, executors of those
estates, heirs, beneficiaries and agents, (“Releasors”) release and discharge Funders and its respective current and
former predecessors, successors, parents, affiliates, subsidiaries, and all of the aforementioned’ s respective agents,
employees, officers, directors, shareholders, attorneys (The Faskowitz Law Firm, PLLC), collection agencies, credit reporting
agencies and vendors (“Releasees”) from all claims of any kind (including any claims for damages, interest, fees and/or
attorney’s fees) that it may have with respect to the Account, or any other matter between Releasors and Releasees, including
without limitation, all claims that were asserted or could have been asserted in the Litigation as of the date of this Agreement.
Merchants further agree that it will not file any claims, complaints, affidavits, arbitrations or proceedings with any regulatory
or administrative agency with respect to the matters released in this Agreement against any of the aforementioned, and any such
claims, complaints, affidavits, arbitrations or proceedings filed prior to the execution of this Agreement shall promptly be dismissed
or withdrawn. This Agreement is intended to resolve forever the entire disagreement between Releasors and Releasees.


 




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In
consideration of the Settlement Payment and subject to the terms and conditions set out in this Agreement, and other good and
valuable consideration, receipt of which is hereby acknowledged, Funders, their predecessors, successors, assigns, estates, executors
of those estates, heirs, beneficiaries, parents, affiliates, subsidiaries, agents, employees, officers, directors, shareholders,
attorneys (including, but not limited to, The Faskowitz Law Firm PLLC) (“Releasors”), releases and discharges Merchants
and all its successors, assigns, estates, executors of those estates, heirs, beneficiaries and agents (“Releasees”)
from any and all present and future actions, causes, causes of action, covenants, contracts, claims, losses, liabilities, and
demands whatsoever, whether based on any federal, state, local or municipal law, act, ordinance, statute, regulation or rule (whether
known or unknown at the time of execution of this Agreement), any common law, any public policy, and any contract or agreement
(whether oral or written, express or implied), or otherwise, that Releasors had, have or may have (whether known or unknown, contingent
or liquidated, choate or inchoate, or otherwise) against Releasees by reason of, arising out of, relating to, or otherwise in
connection in any way with, the acts or omissions to act of Releasees from the beginning of time through and including the date
of this Release.


 


	 	12.	This
    offer is only valid if executed by 5PM EST on 10/25/2018.


 


SIGNING
PAGE TO FOLLOW:


 




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Dated:
10/25/2018


 


	FOR
    MERCHANTS:	 	FOR
                                         FUNDERS:



	 	 	 	 	 
	BY:		 	BY:	

	 	360
    IT Solutions Inc/ US IT Solutions, Inc/ 

Alliance Micro, Inc./ Vivos IT, LLC/ 

Vivos Global Services, LLC/ Vivos Holdings, LLC/
    

Vivos Acquisitions, LLC/ Maslow Media Group, Inc.	 	 	David
                                         Epstein, Esq.

        THE
        FASKOWITZ LAW FIRM, PLLC

        As
        Attorneys for Funders 

        61-43 186 Street, 

        Suite 207 Fresh Meadows, NY 11365 

        (718) 407-2464



 


	BY:		 
	 	Silvija
    Valleru	 
	 	 	 
	BY:		 
	 	Naveen
    Doki	 


 


Please
note that we are required, under Federal Law, to advise you that we are debt collectors and any 

information we obtain will be
used in attempting to collect this debt


 




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