SETTLEMENT AND RELEASE AGREEMENT 

. l. 

This Settlement and Release Agreement ("Agreement") is made by, between, and among 

the following undersigned patties: 

The PJaintiffFederal Deposit Insurance Corporation as Receiver for Pacific Coast 

National Bank ("FDIC-R"), Defendants David L. Adams, Stanley M. Cruse, Colin M. Forkner, 

Richard W. Grinyer, Michael S. Hahn, and Michael V. Cummings (collectively the "Settling 

Defendants"), and St. Paul Mercury Insurance Company C'Insurer") (individually, the FDIC-R, 

the Settling Defendants, and the Insurer may be refened to herein as "Party" and collectively as 

the "Pat1ies"). 

RECITALS 

WHEREAS: 

Prior to November 13, 2009, Pacific Coast National Bank ("Bank") was a depository 

institution organized and existing under the laws of the United States. 

On November 13, 2009, the Office of the Comptroller of the Cunency closed the Bank 

and pursuant to 12 U.S.C. § 1821(c), the Federal Deposit Insurance Corporation was appointed 

Receiver. 

On November 6, 2012, the FDIC-R filed a complaint for money damages against the 

Settling Defendants, each of whom served at various times as a director and/or officer of the 

Bank. Those claims for damages are now pending in the United States District Court for the 

Central District of California in the case styled FDIC as Receiver for Pacific Coast National 

Bank v. Hahn et al., Case No. 12-cv-01938 C'D&O Action"). The Settling Defendants have 

denied liability in the D&O Action. 

Insurer issued a director and officer liability policy numbered EC061 00 1 02 for the period 

June 5, 2008 to May 5, 2009 t"Policy"), which insured the directors and officers of the Bank 

according to the terms, provisions, and conditions of the Policy. The Settling Defendants 

asserted c]aims for coverage under the Policy. Insurer issued a reservation of rights in response 
to the D&O Action, stating it would advance defense costs subject to a full reservation of rights, 

including the rights to deny coverage under the Policy for claims asserted by the FDIC-R against 

the Settling Defendants and to seek reimbursement of advanced defense costs. Additionally, on 

March 12, 2013, Insurer filed a declaratory judgment action against the FDIC-R and the Settling 

Defendants seeking a declaration of its rights and obligations under the Policy with regard to the 

claims asserted by the FDIC-R in the D&O Action. That action was ±1led in the United States 

District Court for the Central District of California in the case styled St. Paul Mercury Ins. Co. v. 

Hahn et al., Case No. 13-cv-00424 ("Coverage Action"), and it is now pending in the United 

States Court of Appeals for the Ninth Circuit. 

The undersigned Pruties deem it in their best interests to enter into this Agreement to 

avoid the uncertainty and expense of further litigation of the D&O Action. 

NOW, THEREFORE, in consideration of the promises, undertakings, payments, and 

releases stated herein, the sufficiency of which consideration is hereby acknowledged, the 

undersigned Parties agree, each with the other, as follows: 

SECTION 1: Payment to the FDIC-R 

A. As an essential covenant and condition to this Agreement, on or before thirty (30) 

calendar days following the date the Parties fully execute this Agreement and the FDIC-R 

provides wire transfer instructions (whichever occurs last) ("First Settlement Payment Date"), 

the Insurer agrees to pay the FDIC-R the sum of one million dollars ($1,000,000.00) ("the First 

Settlement Payment"). Further, if it is determined by the Ninth Circuit Court of Appeals in the 

current appeal of the Coverage Action or in a non-appealable final order after remand in the 

Coverage Action that there is coverage under the Policy for the D&O Action and/or this 

Settlement, within thhty (30) calendar days of such an order and when the FDIC-R provides wire 

transfer instructions (whichever occurs last) ("Second Settlement Payment Date"), Insurer agrees 

to pay the FDIC-R an additional six hundred and fifty thousand dollars ($650,000.00) ("Second 

Settlement Payment"). In the event of a procedural dismissal of the Coverage Action that does 

not reach the merits of the coverage issues and that is final and non-appealable, Insurer shall pay 

2 
the FDIC-R three hundred and twenty-five thousand dollars ($325,000.00) as the Second 

Settlement Payment within thitty (30) days of such a final and non-appealable order and receipt 

of wire transfer instructions from the FDIC-R (whichever comes last). However, if it is 

detetmined in a non-appealable final order in the Coverage Action that there is not coverage 

under the Policy for the D&O Action and/or this Settlement, Insurer would have no additional 

obligation to the FDIC-R under the Policy. Insurer will not seek to recover any portion of the 

First Settlement Payment from the FDIC-R at any time. Insurer and the Settling Defendants 

agree that they will not in any forum contend that the FDIC-R is subject to any claim in the 

nature of reimbursement or recoupment of defense costs or any claim for any amounts that are 

contended or found to be not covered by the Policy. 

B. The Insurer shall deliver the First Settlement Payment, and if applicable the 

Second Settlement Payment, to the FDIC-R by direct wire transfer into an account designated by 

the FDIC-R by notice to the attomeys for the Settling Defendants and Insurer or by cettified or 

cashier~s check drawn upon a depository institution acceptable to the FDIC-R. In the event that 

the First Settlement Payment is not delivered to the FDIC-R (or its counsel) by the First 

Settlement Payment Date, interest shall accrue on all unpaid amounts at the rate of 5% per 

annum from the First Settlement Payment Date until the date of payment. In the event that the 

Second Settlement Payment is not delivered to the FDIC-R (or its counsel) by the Second 

Settlement Payment Date, interest shall accrue on all unpaid amounts at the rate of 5% per 

annum from the Second Settlement Payment Date until the date of payment. Any interest owed 

due to the failure to timely make the First Settlement Payment or the Second Settlement Payment 

shall be solely the responsibility of the Insurer. 

C. If the FDIC-R does not receive the First Settlement Payment in full on or before 

the First Settlement Payment Date, then the FDIC-R, in its sole discretion, shall have the right at 

any time prior to receipt of the First Settlement Payment in full (including all accrued interest) 

to: 

1. Extend the period of time for the First Settlement Payment, including 

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interest accruing fi·orn the date detetmined by subsection A above> through the date of payment 

at a rate calculated in accordance with 26 U.S.C. § 6621(a)(2); or 

2. Enforce this Agreement, in which event the Settling Defendants and 

Insurer agree to jurisdiction in United States District Comt for the Central District of California, 

and the Insurer agrees to pay all of the FDIC-R's reasonable attorney's fees and costs expended 

in enforcing the tenus of this Agreement; or 

3. Tenninate the Agreement, return all previously paid Settlement Payments 

(including any interest paid), move to vacate any dismissal order, to which the Settling 

Defendants and Insurer agree to consent, and re-institute an action on the FDIC-R's claims. The 

Settling Defendants and Insurer further agree to waive any defense based on any stantte of 

limitations that would bar any of the FDIC-R's claims and waive all objections, defenses> claims 

or counterclaims, and covenant and agree not to assett any objections, defenses> claims or 

counterclaims, that did not exist or were otherwise unavailable as of the date this Agreement was 

fully executed; and/or 

4. Seek any other relief available to it in law or equity. 

Any extension of time under Section I. C.l for delivery of the First Settlement Payment or 

acceptance of a portion of the First Settlement Payment shall not prejudice the FDIC-R's rights 

to take any of the actions set forth in Section I.C.2 tlu·ough I.C.4 at any time prior to receipt of 

First Settlement Payment (including all accrued interest) in full. 

D. The Settling Defendants hereby assign only their right, if any, to recover the 

$1 >650,000 (the aforementioned First and Second Settlement Payment amounts) under the 

Policy, but not their obligations under the Policy, to the FDIC-R. 

SECTION II: Stipulation and Dismissal 

A. Within ten business days after the latter of ( 1) full execution of this Agreement by 

all of the Parties> and (2) receipt of the First Settlement Payment, plus any accrued interest, the 

FDIC-R shall file a stipulation of dismissal with prejudice, executed by the attomeys for all 

Patties hereto in the form attached hereto as Exhibit A, in the D&O Action and Insurer shall file 

4 
a stipulation of dismissal of the Sett]ing Defendants, with prejudice with the Settling Defendants 

bearing their own fees and costs, executed by the attorneys for all Parties hereto in the fom1 

attached hereto as Exhibit B, in the Coverage Action. 

B. The Pru.ties acknowledge that this Agreement does not resolve the Coverage 

Action. The Parties acknowledge and agree that there remains a case or controversy among the 

Pruties with respect to the Coverage Action, and the Patties agree that they will not contest the 

standing of any party to the appeal of the Coverage Action, raise the issue of whether the United 

States Comt of Appeals or the United States District Court for the Central District of Califomia 

(collectively, the "Courts") have jurisdiction to decide the Coverage Action on its merits, or 

contend that this Agreement has rendered the Coverage Action moot in any f01urn. The Parties 

reserve all oftheir rights to continue the Coverage Action thmugh the appeal and to a final, nonappealable judgment. If the Courts or anyone else raises the issue of jmisdiction or mootness in 

the Coverage Action, the Parties will affirmatively argue that tllis Settlement has no impact on 

the Coverage Action. The Parties agree that Travelers' complaint (St. Paul Mercury Ins. Co. v. 

Hahn et al., Case No. 13-cv-01866, which was consolidated with the Coverage Action) was 

timely filed and in accordance with 12 U.S. C.§ 1821(d)(6), which properly confers jurisdiction 

on the Courts. If the Coutts question jurisdiction under 12 U.S.C. § 1821, the Patties agree to 

argue that jurisdiction is proper under that statute. 

SECTION III: Releases 

A. The FDIC-R's Releases. 

Upon receipt of the First Settlement Payment in full and except as provided in 

Section III.D., the FDIC-R, for itself and its successors and assigns, hereby releases and 

discharges: 

1. The Settling Defendants and their respective heirs, executors, trustees, 

administrators, representatives, successors, and assigns, from any and all claims, demands, 

obligations, damages, actions, and causes of action, direct or indirect, in law or in equity, 

belonging to the FDIC-R, that arise from or relate to, the performance, nonperformance, or 

5 
matmer ofperfonnance of the Settling Defendants' respective functions, duties and actions as 

officers and/or directors of the Bank including without limitation the causes of action alleged in 

the D&O Action. 

2. All other fanner directors, officers, and employees of the Bank 

(collective]y, the "Covered Persons") and their respective heirs, executors, tmstees, 

administrators, representatives, successors, and assigns, from any and all claims, demands, 

. obligations, damages, actions, and causes of action, direct or indirect, in law or in equity, 

belonging to the FDIC-R, that arise from or relate to, the performance, nonperformance, or 

mrumer ofperfonnance ofthe Covered Persons' respective functions, duties and actions as 

directors, officers and/or employees of the Bank including without limitation the causes of action 

alleged in the D&O Action. This release shall be null and void as to any Covered Person if such 

Covered Person asselts any claim against the FDIC-R. 

B. The Settling Defendants' Release. 

1. Effective simultaneously with the release granted in Section liLA. above, 

the Settling Defendants, on behalf of themselves individually, and their respective heirs, 

executors, trustees, administrators, agents, representatives, successors, and assigns, hereby 

release and discharge the FDJC-R, and its employees, officers, directors, representatives, 

successors and assigns, from any and all claims, demands, obligations, damages, actions, and 

causes of action, direct or indirect, in law or in equity, that mise from or relate to, the Bank or to 

the performance, nonperformance, or manner ofperf01mance ofthe Settling Defendants' 

respective functions, duties and actions as officers and/or directors of the Bank including without 

limitation the causes of action alleged in the D&O Action. 

2. Effective simultaneously with the release granted in Section III.A. above, 

the Settling Defendants, on behalf of themselves individually, and their respective heirs, 

executors, trustees, administrators, agents, representatives, successors, and assigns, hereby 

release and discharge each other from any and all claims, demands, obligations, damages, 

actions, and causes of action, direct or indirect, in law or in equity, that arise from or relate to the 

6 
performance, nonperformance, or manner of performance of their respective ftmctions, duties 

and actions as officers and/or directors of the Bank. 

3. Effective simultaneously with the release granted in Section liLA. above 

and after Insurer pays all of the Settling Defendants' Defense Costs for the D&O Action subject 

to the limitation that no additional payments will be made once the Policy's original $6 million 

limits of liability are at $1.65 million (excluding from this calculation of remaining limits any 

payment made to the FDIC-R pursuant to this Agreement), the Settling Defendants, on behalf of 

themselves individually, and their respective heirs, executors, trustees, administrators, agents, 

representatives, successors, and assigns, hereby release and discharge Insurer, its parents, 

subsidiaries, affiliates and reinsurers, and their respective employees, oflicers, directors, agents, 

representatives, successors, and assigns, from any and all claims, demands, obligations, damages, 

fees, costs, interest, actions and causes of action (contractual, extra-contractual, statutory, or 

regulatory), direct or indirect, in law or in equity, that arise from or relate to the Policy, the D&O 

Action, and/or the Coverage Action. The sole exception to this Release is the Settling 

Defendants' claims for coverage for the $1.65 million combined potential Settlement Payments 

which are assigned to the FDIC-R pursuant to Section I.D. above. 

C. The Insurer's Release. 

Effective simultaneously :with the releases granted in Section liLA. above, Insurer, for 

itself and its successors and assigns, and on behalf of its parents, subsidiaries, affiliates and 

reinsurers, and their successors and assigns, hereby releases and discharges the Settling 

Defendants and their respective heirs, executors, trustees, administrators, representatives, 

successors, and assigns, from any and all claims, demands, obligations, damages, actions, and 

causes of action, direct or indirect, in law or in equity, related to the Policy or that arise from or 

relate to, the claims or causes of action alleged in the D&O Action, including any rights of 

reimbursement or recoupment of defense costs, the First Settlement Payment, and/or the Second 

Settlement Payment. 

7 
D. Exceptions from Releases bv the FDIC-R. 

I. Notwithstanding any other provision ofthis Agreement, the FDIC-R does 

not release, and expressly preserves fully and to the same extent as if this Agreement had not 

been executed, any claims or causes of action: 

a. Against the Settling Defendants or any other person or entity for 

liability, if any, incuned as the maker, endorser or guarantor of any promissory note or 

indebtedness payable or owed by them to the FDIC-R, the Bank, other financial institutions, or 

any other person or entity, including without limitation any such claims acquired by the FDIC-R 

as successor in interest to the Bank or any person or entity other than Banlc; and 

b. Against any person or entity not expressly released by the FDIC-R 

in this Agreement. 

2. Notwithstanding any other provision of this Agreement, nothing in this 

Agreement shall be constmed or interpreted as limiting, waiving, releasing, or compromising the 

jurisdiction and authority of the Federal Deposit Insurance Corporation in the exercise of its 

supervisory or regulatory authority or to diminish its ability to institute administrative 

enforcement or other proceedings seeking removal, prohibition, or any other relief it is 

authorized to seek pursuant to its supervisory or regulatory authority against any person. 

3. Notwithstanding any other provision of this Agreement, this Agreement 

does not purport to waive, or intend to waive, any claims that could be brought by the United 

States tluough the Department of Justice, the United States Attomey's Office for any federal 

judicial district, or any other depatiment or agency of the United States as defined by 18 U.S.C. 

§ 6. In addition, the FDIC-R specifically reserves the right to seek coutt-ordered restitution 

pursuant to the relevant provisions of the Mandatory Victims Restitution Act, 18 U.S.C. §§ 3322 

and 3663 et. seq., if appropriate. 

SECTION IV: Waiver of Dividends and Proceeds from Litigation 

To the extent, if any, that Settling Defendants are or were shareholders of the Bank or its 

holding company and by virtue thereof are or may be entitled to a dividend, payment, or other 

8 
distribution upon resolution of the receivership of the Banl( or proceeds in any litigation that has 

been or could be brought against the Federal Deposit Insurance Corporation in any capacity or 

against the United States based on or arising out of, in whole or in part, the closing of the Bank, 

or any alleged acts or omissions by the Federal Deposit Insurance Cmporation in any capacity, 

the United States government, or any agency or department of the United States government in 

connection with the Bank, its conservatorship, or receivership, Settling Defendants hereby 

knowingly assign to the FDIC-R any and all rights, titles, and interest in and to any and all such 

dividends, payments, or other distributions, or proceeds. 

SECTION V: California Civil Code Section 1542 

The Parties acknowledge that they are familiar with California Civil Code Section 1542, 

which reads that: "A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE 

CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE 

TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER MUST 

HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR." 

Each of the Pru.ties acknowledges that such Patty may have sustained damages in 

connection with the Claims that m·e presently unknown and unsuspected, and that such damages 

as the Pru.ty may have sustained in connection with the Claims might give rise to additional 

damages in the future. Neve1theless, each of the Parties acknowledges that this Agreement has 

been negotiated and agreed upon in light of such possible damages and each Party expressly 

waives any and all rights under Califomia Civil Code Section 1542 and under any other federal 

or state statute or law of similar effect in connection with the Claims. Each Party acknowledges 

and agrees that this waiver is an essential and material te1m of this Agreement, and that, without 

such waiver, this Agreement would not have been entered. 

SECTION VI: Representations and Acknowledgements 

A. . Authorized Signatories. All of the undersigned persons represent and wanant that 

they m·e Parties hereto or are authorized to sign this Agreement on behalf of the respective Party, 

and that they have the fu11 power and authority to bind such Party to each and every provision of 

9 
this Agreement. This Agreement shall be binding upon and inure to the benefit of the 

undersigned Parties and their respective heirs, executors, trustees, administrators, representatives, 

successors and assigns. 

B. Advice of Counsel. Each Party hereby acknowledges that he, she, or it has 

consulted with and obtained the advice of counsel prior to executing this Agreement, and that 

this Agreement has been explained to that Party by his or her counsel. 

C. Financial Disclosure Representation. Each Settling Defendant has submitted 

financial information to the FDIC-R including verified personalfinancial statements and herein 

affi1ms that his fmancial infonnation is true.and accurate as of the date of this Agreement. Each 

Settling Defendant expressly acknowledges that, in dete1mining to settle the claims released 

herein, the FDIC-R has reasonably and justifiably relied upon the accuracy of the financial 

information submitted by the Settling Defendants. TI1e FDIC-R has no obligation to 

independently verify the completeness and accuracy of that financial information. 

SECTION VII: Reasonable Cooperation 

The Parties agree to cooperate in good faith to effectuate all the te1ms and conditions of 

this Agreement, including doing, or causing their agents and attorneys to do, whatever is 

reasonably necessary to effectuate the signing, delivery, execution, filing, recording, and entry, 

of any documents necessary in the D&O Action, the Coverage Action, and. to otherwise perform 

the tenns of this Agreement. 

SECTION VIII: Other Matters 

A. No Admission of Liabilitv or Coverage. The undersigned Parties each 

acknowledge and agree that the matters set forth in this Agreement constitute the settlement and 

compromise of disputed claims and defenses, that this Agreement is not an admission or 

evidence of liability, insurance coverage, or infirmity by any of them regarding any claim or 

defense, and that the Agreement sha11 not be offered or received in evidence by or against any 

Pruiy except to enforce its tem1s. 

B. Execution in Counterparts. This Agreement may be executed in counterparts by 

10 
one or more ofthe Parties and all such counte1parts when so executed shall together constitute 

the final Agreement, as if one document had been signed by all Parties; and each such 

counterpart, upon execution and delivery, shall be deemed a complete original, binding the 

Parties subscribed thereto upon the execution by all Parties to this Agreement. 

C. Choice of Law. This Agreement shall be interpreted, construed and enforced 

according to applicable federal law, or in its absence, the laws of the State of California. 

D. Notices. Any notices required hereunder shall be sent by registered mail, first 

class, return receipt requested, and by email, to the following: 

Ifto the FDIC-R: Bryce Quine, Counsel 

Federal Deposit Insurance Corporation 

1601 Bryan Street 

Dallas, TX 75201 

(b)(6) __________ _ I I 

If to the Settling Defendants: 

(b)(6) 

(b)(6) __________ _ 

If to the Insurer: 

(b)(6) 

(972) 761-8520 

Peter K. Rosen 

Latham & Watkins LLP 

3 55 South Grand A venue 

Los Angeles, CA 90071-1560 

I · I 

(213) 891-8778 

(Attorney for Mr. Adams, Mr. Cruse, 

Mr. Forkner, and Mr. Cummings) 

Alan A. Greenberg 

Greenberg Gross LLP 

650 Tovvn. Center Drive, Suite 1750 

Costa Mesa, CA 92626 

(949) 383-2800 

(Attorney for Mr. Grinyer and Mr. Hahri) 

Thomas J. Judge 

TI10mpson, Loss & Judge, LLP 

Two Lafayette Centre · 

1133 21st Street, NW, Suite 450 

Washington DC 20036 I ················· I 

(202) 778-4065 

II 
(b)(6) 

E. Entire Ahrreement and Amendments. This Agreement constitutes the entire 

agreement and understanding between and among the undersigned Patties concerning the matters 

set forth herein and supersedes any prior agreements or understandings. This Agreement may 

not be amended or modified, nor may any of its provisions be waived, except in vvriting signed 

by the Patties bound thereby, or by their respective authorized attorney(s), or other 

representative( s ). 

F. Titles and Captions. All section titles and captions contained in this Agreement 

are for convenience only and shall not affect the interpretation of this Agreement. 

G. No Confidentiality. The undersigned Parties acknowledge that this Agreement 

shall not be confidential and will be disclosed pursuant to the Federal Deposit Insurance 

Corporation's applicable policies, procedures, and other legal requirements. 

IN WITNESS WHEREOF, the Pa1ties hereto have caused this Agreement to be executed 

by each of them or their duly authorized representatives on the dates hereinafter subscribed. 

01·"1~/,r Date: '-' ! " r I i ~ 

Date: ____ _ 

Date: ____ _ 

FEDERAL DEPOSIT INSURANCE CORPORATION AS 

i!:EIVEB. FQR PA!:IFI!: Q;!AST NATIONAL BANK 

< I 

By: Bryce Quine 

Title: Counsel, Legal Division 

SETTLING DEFENDANTS: 

David L. Adams 

Stanley M. Cruse 

12 
E. Entire Agreement and Amendments. This Agreement constitutes the entire 

agreement and understanding between and among the undersigned Parties concerning the matters 

set forth herein and supersedes any prior agreements or understandings. This Agreement may 

not be amended or modified, nor may any of its provisions be waived, except in writing signed 

by the Parties bound thereby, or by their respective authorized attomey(s), or other 

representative( s ). 

F. Titles and Captions. All section titles and captions contained in this Agreement 

are for convenience only and shall not affect the interpretation of this Agreement. 

G. No Confidentiality. The undersigned Parties acknowledge that this Agreement 

shall not be confidential and will be disclosed pursuant to the Federal Deposit fusurance 

Corporation's applicable policies, procedures, and other legal requirements. 

IN WITNESS WHEREOF, the Parties hereto have caused this Agreement to be executed 

by each of them or their duly authorized representatives on the dates hereinafter subscribed. 

Date: ___ _ 

Date: ____ _ 

FEDERAL DEPOSIT INSURANCE CORPORATION AS 

RECEIVER FOR PACIFIC COAST NATIONAL BANK 

By: Bryce Quine 

Title: Counsel, Legal Division 

SETTLING DEFENDANTS: 

Stanley M. Cruse 

12 
(b)(6t .... 

E. Entire Agreement and Amendments. This Agreement constitutes the entire 

agreement and understanding between and among the undersigned Parties concerning the matters 

set forth herein and supersedes any prior agreements or understandings. This Agreement may 

not be amended or modified, nor may any of its provisions be waived, except in writing signed 

by the Pa11ies botmd thereby, or by their respective authorized attorney(s), or other · 

representative( s). 

F. Titles and Captions. All section titles and captions contained in this Agreement 

are for convenience only and shall not affect the interpretation of this Agreement. 

G. No Confidentiality. The undersigned Parties acknowledge that this Agreement 

shall not be confidential. and will be disclosed pursuant to the Federal Peposit Insurance 

Corporation's applicable policies, procedures, and other legal requirements. 

IN WITNESS WHEREOF, the Parties hereto have caused this Agreement to be executed 

by each of them or their duly authorized representatives on the dates herein~er subscribed. 

Date: - ---

Date: _ ___ _ 

................................................................................. 

······························ 

FEDERAL DEPOSIT INSURANCE CORPORATION AS 

RECEIVER FOR PACIFIC COAST NATIONAL BANK 

By: Bryce Quine ·· 

Title: Counsel, Legal Division 

SETTLING DEFENDANTS: 

David L. Adams 

......................................... ································ 

· .. Cruse 

l2 
(b)(6)_ --=-----=--r---f-=------I------ Date: ~zJ..- Colin M. Forkner 

Date: ___ _ 

Richard W. Grinyer 

Date: ___ _ 

MichaelS. Hahn 

...... 

Date: _ __ _ 

Michael V. Cummings 

ST. PAUL MERCURY INSURANCE COMPANY 

Date: ___ _ 

By: 

Title: 

13 
Date: _· __ _ 

Colin M. Forkner 

(b)(6) ___ _ --;----;r--- - -+- ----

Date: c1'6A6/io !$ 

Richard W. Grinyer 7 

·. Date: ___ _ 

MichaelS. Hahn · 

Date: ___ _ 

Michael V. Cummings 

ST. PAUL MERCURY INSURANCE COJvlPANY 

Date: ___ _ 

By: 

Title: 

13 

I 

I 

I 

l 

I 

., 

I 
Date: ___ _ 

Colin M. Forkner 

Date: ---- Richard Vv". Grinyer 

(b )(6) .................................................................... ..................................... 

Date: 

Date: ___ _ 

Michat:l V. Cummings 

ST. PAUL MERCURY INSURANCE COMPANY 

Date: ___ _ 

By: 

Title: 

L3 
Date: ___ _ 

ColinM. Forkner 

Richard W• Grinyer 

Date: ___ ...._ 

Mi.chaeJ S, Balm 

Kb)(6) I ...... . I 

I i ·,J 

I· €. ·-·· 

Dat~:. -~ -J. tc ·- l5. ·········································································IL.."":' ... ~~~~---.------.,.....___. 

Micha¢1 v. CUllUl1i.rlgs J 

ST. PAUL MERCURY_ThTSURANCE COMPANY 

By: 

Title: .•: 

r 

l3 
·Date: __ _ 

Colin M. Forkner 

Date: _ _ _ _ 

Richard W. Grinyer 

Date: __ _ 

Michael S. Hahn 

Date: __ _ 

Michael V, Cummings 

ST. PAUL MERCURY INSURANCE COMPANY 

rb)(6L_ __ · -- -- ----.. ~-

! Date: fE Ld..St l ~ 

13