SETTLEMENT AGREEMENT AND OPTION FOR RELEASE . (b)(6) 

tel . 

THIS SETILEMENT AGREEMENT AND OPTION FOR ASE . --. 

· ("Settlement Agreemenf') is entered into and made effective as ofthe y of 

Ot"'a.,.-oSbptembu, 2011 (''Effective Date'1, by and between the Federal Deposit = Insurance 

Corporation as Receiver for lndyMac Bank, FSB (''FDIC-R") and Luxury Mortgage·'----r--...,--...:-' ~- \ l 

Corporation ("LUXURY "). The FDIC-R and LUXURY may hereinafter be referred to '\.,.. .; 

individually as a "Party" or collectively as the "Parties". 

RECITALS 

1.1 WHEREAS, on or about July J9, 2010, the FDIC-R filed a lawsuit 


against LUXURY entitled FEDERAL DEPOSIT INSURANCE CORPORATION as 


Receiverfor INDYMAC BANK. F.S.B. v. LUXURYMORTGAGE CORPORATION, in 


the United States District Court, Central District ofCalifornia, Cas e No. CVl 0-5270. 


(hereinafter "the Curtiss Action''). 


1.2 WHEREAS, on or about September 8, 2011, the FDIC-R filed a lawsuit 


against Ll.JXllRY entitled FEDERAL DEPOSITINSURANCE CORPORATION as 


Receiverfor INDYMAC BANK, F.S.B. v. LUXURYMORTGAGE CORPORATION, in 


the United States District Court, Central District ofCalifornia, Case No. CVI 1-07402 


(hereinafter, the "Hampton Action''). 


1.3 WHEREAS, Luxury has denied the FDIC-R's allegations in both the 


Curtiss Action and the Hampton Action (collectively, "the Actions''). 


1.4 WHEREAS, without admitting liability, the Parties desire to and have 


agreed to enter into this Settlement Agreement relating to the Actions upon the tenns 


and conditions hereinafter set forth. 


AGREEMENT 

NOWt THEREFORE, in consideration ofthe mutual covenants and promises set 


forth herein, and for other good and valuable consideration, the receipt and sufficiency of 


which are hereby acknowledged by the Parties, the Parties, intending to be legally bound, 


agree as follows: 


1.5 Recitals. The Recitals set forth above are incorporated into the body of 


this Settlement Agreement as though fully set forth herein. 


1.6 Payment of the Settlement Funds. LUXURY shall pay the total sum 


ofOne Hundred Fifteen Thousand Dollars ($115,000) (the "Settlement Funds"). 


SETILEMENT AGREEMENT & OPTION FOR RELEASE 

Page I ofiO 
(b)(4),(b)(6) 

Payment of the Settlement Funds shall be according to the payment schedule set forth 

in paragraph 1.8 below. The Settlement Funds shaH constitute the first $115,000 of 

payments due under the payment schedule. 

1.7 LUXURY's Release Option. LUXURY has the opportunity, but not 

the obligation, to obtain from the FDIC-R a release ofany claims arising out of any 

loans which it ever originated and were sold to IndyMac Bank, F.S.B. by LUXURY 

(the "LOANS'') (the "Release Option"). 

a. ffLUXURY elects to invoke the Release Option, then 

LUXURY must notify the FDIC-R, in writing, no later than July 31,2013, of its exercise 

ofthe Release Option. Timely notice shall be given via mail, facsimile or electronic mail 

to: Michael H. Delbick, Esq., Mortgage Recovery La{ Grouu. LLP. 700 North Brand 

Boulevard, Suite 830, Glendale, CA 91203; facsimile -- - · .. Jeiectronic mail:_ 

1- -- --- ... ... -- - ·· - I 

b. If LUXURY elects to invoke the Release Option, then 

LUXURY shall pay to the FDIC-R an additional Eighty Thousand Dollars ($80,000) (the 

"Release Settlement Payment"). The Release Settlement Payment shall be in addition to 

the amount of the Settlement Funds and shall bring the total amount payable by 

LUXURY to the FDIC-R under this Settlement Agreement to One Hundred Ninety-Five 

Thousand Dollars ($195,000). Payment ofthe Release Settlement Payment shall be 

according to the payment schedule set forth in paragraph 1.8, below. 

c. If LUXURYgives (1) timely notice ofLUXURY's intent to 

exercise the Release Option as set forth herein, and (2) pays the Settlement Funds, then 

and only then shall the release of claims provisions set forth below become effective. 

d. IfLUXURY elects not to invoke the Release Option, then 

LUXURY does not need to provide any further notice to the FDIC-R. IfLUXURY has 

not effectively exercised the Release Option on or before July 31, 2013, then effective 

August I, 2013, the Release Option is automatica1ly deemed rejected. 

e. IfLUXURY does not timely invoke the Release Option, 

then the FDIC-R is free to pursue any claims against LUXURY, including (but not 

limited to) the claims set forth in the Hampton Action, the Curtiss Action, this Settlement 

Agreement and any other claims arising out of the LOANS. Should the FDIC-R pursue 

any claims against LUXURY, the payments made by LUXURY under this Settlement 

Agreement will be offset against any future obligation or judgment. 

1.8 Payment Schedule. Payment to the FDIC-R by LUXURY ofthe 

Settlement Funds and, ifapplicable, the Release Option, shall be made according to the 

following schedule: 

SETILBMENT AGREEMENT & OPTION FOR RELEASE 


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l 

! 

(b)(4),(d)(6) 

t 
For payment of the Settlement Funds: 

Within ten (lO) business days ofexecution ofthis Agreement by both parties, 

LUXURY shall make a payment of Twenty-Five Thousand Dollars ($25,000). 

On or before January 15, 2012, LUXURY shall make an additional payment of 

Twenty-Five Thousand Dolim {$25,000). 

On or before July 15, 2012, LUXURY shall make an additional payment of 

Fifteen Thousand Dollars ($15,000). 

On or before January 15, 2013, LUXURY shaH make an additional payment of 

Fifteen Thousand Dollars ($15,000). 

On or before July 15, 2013, LUXURY shall make an additional payment of 

Twenty-Five Thousand Dollars ($25,000). 

On or before January 15, 2014, LUXURY shall make an additional payment of 

Twenty-Five Thousand Dollars ($10,000). 

IfLUXURY exercises the Release Option, then for payment ofthe Release 

Settlement Payment: 

On or before January 15, 2014, LUXURY shall make an additional payment of 

Fifteen Thousand Dollars {$15,000). 

On or before July 15, 2014, LUXURY shall make a payment of Twenty-Five 

Thousand Dollars ($25,000). 

On or before January 15, 2015, LUXURY shall make a payment ofTwenty-Five 

Thousand Dollars ($25,000). 

On or before July 15, 2015, LUXURY shall make a payment of Fifteen Thousand 

Dollars ($15,000). 

1.9 Payments shall be made by wire transfer made oavable to "Mortgage 

Recovc~ Law GrouJ Trust Account," Account Numbe9 (b)(4) · ··...... ·fRouting _ (b)(4) Number~ . · Reference: Luxury Settlement 

1.10 Payments ofthe Settlement Funds and, ifapplicable, the Release 

Settlement Payment are interest free if timely paid. If LUXURY defaults on any ofits 

payment obligations under this Settlement Agreement and thereafter fails to cure the 

SETILEMENT AGREEMENT & OPTION FOR RELEASE 


Page 3 of 10 

default as provided in Section 1.15 below, an additional I0% interest will begin to 


accrue and be due on any unpaid sums. 


1.11 Financial Documents. Within three days ofreceipt of this Settlement 

Agreement executed by the FDIC-R, LUXURY shaH provide to the FDIC-R a current 

balance sheet and income statement (Financial Documents) for January 1, 2011 through 

June 30, 2011. LUXURY represents and warrants that all ofthe infonnation set forth 

in LUXURY's Financial Documents provided, including the information in the 

Financial Documents provided for years 2008,2009,2010 and 2011 are true and · 

correct. If LUXURY fails to provide the Financial Documents or breaches this 

representation and warranty, then the FDIC-R is free to pursue any claims against 

LUXURY, including (but not limited to) the claims set forth in the Hampton Action, 

the Curtiss Action, this Settlement Agreement and any other claims arising out of the 

LOANS. Should the FDIC-R pursue any claims against LUXURY, the payments made 

by LUXURY under this Settlement Agreement will be offset against any future 

obligation or judgment. 

1.12 Ownership of Claims. The FDIC-R represents and warrants that it has 

not assigned any rights it may have or may have had with respect to repurchase and 

indemnification rights associated with the LOANS, to any other person or entity, 

including, without limitation, IndyMac Federal Bank, OneWest Bank, or any of their 

affiliates. This representation and warranty is a material inducement for Luxury 

entering into this Settlement Agreement and shall survive the execution and delivery of 

the Settlement Agreement. Should a claim be made by IndyMac Federal Bank, FSB, 

OneWest Bank or any oftheir affiliates against Luxury with respect to repurchase and 

indemnification rights associated with the LOANS, Luxury shall notify the FDIC-R of 

such claim, in writing, in the manner set forth in Paragraph 1.7 above_ Upon proper 

notification of such claim by Luxury to the FDIC-R, Luxury shall be relieved ofany 

further payment obligation under this Settlement Agreement until such claim is 

withdrawn against Luxury_ Once such claim has been withdrawn against Luxury, 

Luxury shall resume all payment obligations under this Settlement Agreement when 

due, including payment ofany amount then due under the Payment Schedule set forth 

in Paragraph 1.8 above no later than sixty (60) days after Luxury's receipt of written 

notice to the persons and in the manner identified in Paragraph 1.14 that such claim has 

been withdrawn. 

1.13 Dismissal of Ac:tions. The FDIC-R shall cause its attorneys, with 

cooperation as necessary from LUXURY's attorneys, to execute and file requests for 

dismissal of the Hampton Action and the Curtiss Action, without prejudice_ Dismissal 

of the Curtiss Action and the Hampton Action without prejudice is a material term of 

the settlement. However, ifthe judge presiding over either the Hampton Action or the 

Curtiss Action only allows a dismissal with prejudice, the FDIC-R shall dismiss the 

SETTLEMENT AGREEMENT&. OPTION FOR RELEASE 


Page4 ofiO 

(b)(4),(b)(6) 

(b)(4),(b)(6) 

(b)(4),(b)(6) 

applicable action with prejudice and this Agreement shall remain in full force and 

eff~t. 

1.14 Notice ofDefault. In the event LUXURY defaults by failing to make a 

timely payment to the FDlC-R as set forth in this Settlement Agreement, the FDIC-R 

shall give written notice of the default to LUXURY via mail, facsimile or electronic 

mail to: John Tate, Esq., Davis Wright Tremaine, LLP, 865 S. Fi eroa St., Suite 

2400. Los Angeles. CA 90017, T~ . -- -- IF: · - email: (b)(4),(b)(6)

] -- ·· Iand Cassandra Bums McDonald, Luxury 'f'L'U><.<Lt«i..:..........u....:-r 


(b)(4),(b)(6) Landmark Square, Suite 100, Stamford, Connecticut 06901, T 


(2Q3J 569-4276. email~ -...... ·- ... - · · · ·· - · · I ~----' 

1.15 Time to Cure. LUXURY shall have ten (10) business days from receipt 


of the notice ofdefault to cure the default. IfLUXURY fails to cure a default on the 


payment ofthe Settlement Funds within ten (1 0) business days, the FDIC-R shall retain 


all consideration it received, and it may, in its sole discretion, pursue all legal and nonlegal remedies to recover any portions ofthe Settlement Funds that have not been paid, g· . . (b)(S) 


and/or is free to pursue any claims against LUXURY, including (but not limited to) the · 


claims set forth in the Hampton Action, the Curtiss Action, this Settlement Agreement "\ 


and any other claims arising out of the WANS. If Luxury fails to cure a aut n the q--' 


payment ofthe Release Settlement Payment within ten (10) s, t e FDIC-R shall 


retain all consideration it received, and it may, in its sole discretion. pursue all legal and \:)U$\M¥ 


non-legal remedies to recover any portions ofthe Release Settlement Payment that have D·· 


not been paid. Should the FDIC-R pursue any claims against LUXURY, the payments .(b)(S) ... 


made by LUXURY under this Settlement Agreement will be offset against any future · · ·· · 


obligation orjudgment. 


1.16 Stay and Tolling Agreement. The parties agree that all claims arising 

from the LOANS between the FDIC-R and LUXURY (including but not limited to the 

Curtiss and Hampton Loans and all rights and defenses) are stayed until August I, 

2013. The parties further agree that the applicable statute of limitations for any such 

claims shaH be tolled from the Effective Date ofthis Settlement Agreement through 

July 31,2013. 

1.17 Each Party agrees that Section 664.6 ofthe Code ofCivil Procedure of the 

State ofCalifornia shall apply to this Settlement Agreement and requests that the court 

retain jurisdiction over the Parties to enforce this Settlement Agreement. 

1.18 The Parties shall bear their own costs and attorneys' fees incurred in the 

Actions. 

SE'JTLEMENT AGREEMENT & OPTION FOR RELEASE 


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1.19 Conditional Release. 

a. The FDIC-R's release of any claims arising out ofthe 

LOANS is conditioned upon LUXURY's (1) timely exercise ofthe Release Option and 

(2) the FDIC-R's receipt ofthe Settlement Funds. Ifthe conditions herein for a release 

are met, FDIC-R agrees that the release set forth in Sections 1.20, 1.21, 1.22, 1.23, and 

1.24 shall become effective immediately without further action by either party. 

b. If the conditions herein for a Release Option are met, then 

LUXURY agrees that the release set forth in Sections l.20, 1.21, 1.22, 1.23, and 1.24 

shall become effective immediately without further action by either party. 

1.20 Unknown Claims. Ex.cept for the obligations arising under this 

Settlement Agreement, each Party acknowledges that this Settlement Agreement 

applies to all claims for injuries, damages, or losses of any type or nature (whether 

those injuries, damages, or losses are known or unknown, foreseen or unforeseen, 

patent or latent) which each Party may have against the other Party arising from the 

obligation to repurchase and/or indemnify for losses associated with the LOANS. Each 

Party hereby expressly waives application of California Civil Code §1542 and any 

other similar statute or rule with respect to the LOANS. 

1.21 Subject to the tenns and conditions set forth in Paragraphs 1.7 and 1.19, 

above, the Parties certify that they have read and under!itood the following provisions 

ofCalifornia Civil Code §1542, which states in pertinent part as follows: 

"A GENERAL RELEASE DOES NOT EXTEND TO 

CLAIMS WHICH Tim CREDITOR DOES NOT KNOW 

OR SUSPECT TO EXIST IN IDS OR HER FAVOR AT 

THE TIME OF EXECUTING THE RELEASE, WHICH IF 

KNOWN BY HIM OR HER MUST HAVE 

MA1ERIALLY AFFECTED HIS OR HER 

SETTLEMENT WITH TIJE DEBTOR." 

1.22 Subject to the tenns and conditions set forth in Paragraphs 1.7 and 1.19, 

above, the Parties mutually fully, finally, and forever release and discharge each other, 

and any and all oftheir respective past, present, and future affiliates, employees, 

members, partners, joint venturers, independent contractors, attorneys, insurers, 

investors, successors, assigns, representatives, officers, directors, shareholders, 

independent contractors, predecessors, successors and assigns, and any corporation, 

1 partnership or limited liability company which was or is at any time the parent or 

wholly owned subsidiary ofsuch entity, and any such cotporation's, partnership's or 

limited liability company's officers, directors, employees, or any cotporation, 

SETII..EMENT AGREEMENT&: OPTION FOR RELEASE 


Page 6 oflO 

partnership or limited liability oompany which was or is an affiliate ofsuch entity by 

virtue ofcommon ownership or control, and any such corporation's, partnership's or 

limited liability company's, officers, directors, and/or employees ofand from any and 

all actions, causes of action, claims, demands, damages, debts, losses, costs, expenses, 

attorney fees or other liabilities ofevery kind and nature whatsoever, whether legal or 

equitable and whether known or unknown, arising out of, resulting from, or relating to, 

in any manner, the obligation to repurchase and/or indemnify for losses associated with 

the LOANS, the claims and causes of action that were or could have been asserted 

relating to the obligation to repurchase and/or indemnify for losses associated with the 

LOANS, or any facts or circumstances related to the obligation to repurchase and/or 

indemnify for losses associated with the LOANS. 

1.23 IDdyMae Only. Notwithstanding any other provision in this Settlement 


Agreement, the FDIC-R does not release, and expressly preserves fully and to the same 


extent as ifthe Settlement Agreement had not been executed any claims against 


LUXURY arising out ofexisting or failed financial institutions other than IndyMac 


Bank. 


1.24 FDIC-R Only. Notwithstanding any other provision. in this Settlement 

Agreement, the FDIC-R does not release, and expressly preserves fully and to the same 

extent as ifthe Settlement Agreement had not been executed any action taken by any 

other federal agency. In addition, this Settlement Agreement does not purport to waive, 

or intend to waive, any claims which could be brought by the United States through 

either the Department of Justice or the United States Attorney's Office for any federal 

judicial district In addition, the FDIC-R specifically reserves the right to seek court 

ordered restitution pursuant to the relevant provisions ofthe Victim and Witness 

Protection Act, 18 U.S.C. § 3663, eJseq., ifappropriate. 

1.25 Conditions of E~~:eentlon. Each Party acknowledges and warrants that 

its execution of this Settlement Agreement is free and voluntary. 

1.26 No Admission. It is agreed that no Party hereto admits liability or 

wrongdoing of any nature, and that this Settlement Agreement is made as a 

compromise ofdisputed claims. 

1.27 Fair Meaning. The Parties hereto further agree that the language of all 

parts ofthis Settlement Agreement shall in all cases be construed as a whole, according 

to its fair meaning, and not strictly for or against any ofthe Parties. 

1.28 Governing Law. The Parties agree to submit to the Courts ofthe 

United States ofAmerican, Central District of California, for any dispute arising out of 

this Settlement Agreement, or related thereto, and consent to the jurisdiction of said 

SE1TLEMENT AGREEMENJ' &. OPTION FOR RELEASE 


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I 
Courts and further agree that any and all matters ofdispute shall be adjudicated, 


governed and controlled under California law. 


1.29 Attorneys' Fees. Should any action be commenced to enforce, 

interpret, or seek damages, injunctive relief, or specific perfonnance for violation of 

this Settlement Agreement, the prevailing party shall, in addition to any other available 

relief, be entitled to an award of reasonable attorney's fees and litigation expenses 

incurred in the prosecution or defense ofthe action, including any appeaL 

1.30 Severability. The Parties hereto agree that ifany provision ofthis 

Settlement Agreement is declared by any court to be illegal or invalid, the validity of 

the remaining parts, terms or provisions shall not be affected thereby, and such illegal 

or invalid part, term or provision shall be deemed not to be part ofthis Settlement 

Agreement. 

1.31 Binding Effect. This Settlement Agreement shall be binding upon and 

inure to the benefit ofthe Parties and their respective heirs, personal representatives, 

successors, and assigns. 

1.32 Review and Understanding. 1be Parties have entered into this 

Settlement Agreement voluntarily, having fully read and fully understanding the 

meaning and effect ofall of its terms and provisions, and fully understanding its and 

their costs and risks. Each Party bas consulted with legal counsel concerning this 

Settlement Agreement and has conducted such inquiry as they deem necessary and 

advisable prior to entering into this Settlement Agreement The Parties enter into this 

Settlement Agreement understanding that facts or other circumstances may exist which 

are presently unknown or undisclosed, or which are different from or other than those 

which they believe to be the case, and the Parties voluntarily assume all risks attendant 

to such unknown, undisclosed, different, or additional facts or other circumstances. 

1.33 Number. Whenever applicable, the singular shall include the plural, 

and the plural shall include the singular. 

1.34 Counterparts/Exeeution. This Settlement Agreement may be executed 

in one or more counterparts, all of which shall form a single agreement. A Party's 

signature on this Settlement Agreement by facsimile shall be valid and effective for all 

purposes as an original signature, provided, however, that the original signature shall be 

produced upon request. 

1.35 Waiver. No term or condition ofthis Settlement Agreement shall be 

deemed to have been waived, nor shall there be an estoppel against the enforcement of 

any provision of this Settlement Agreement, except by written instruments signed by 

the Party charged with the waiver or estoppel. No written waiver shall be deemed a 

SETI'LEMENT AGREEMENT 81. OPTION FOR RELEASE 


PageSofiO 

continuing waiver unless specifically stated therein, and the written waiver shall 

operate only as to the specific term or condition waived, and not for the future or as to 

any other act than that specifically waived. 

1.36 Headings. The beadings of paragraphs herein are intended solely for 

the convenience ofreference and shall not control the. meaning or interpretation ofany 

of the provisions ofthis Settlement Agreement. 

1.37 Subsequent Agreements. The Parties agree that, upon the reasonable 

request ofthe other Party, they shall execute, acknowledge, and de1iver any additional 

instruments or documents that may reasonably be required to carry out the intentions of 

this Settlement Agreement, including such instruments as may be required by the laws 

ofany jurisdiction, now in effect or hereinafter enacted, that may affect the rights of the 

Parties as between themselves or others with respect to their rights and obligations 

created by tbis Settlement Agreement. 

1.38 Entire Agreement. The Parties hereto further agree and promise that 

this Settlement Agreement sets forth the entire agreement between and among the 

Parties with respect to the repurchase and/or indemnification obligations in connection 

with the LOANS, and fully supersedes any and all prior negotiations, agreements or 

understandings made between or among the Parties. This Settlement Agreement shall 

not be modified except in a writing signed by the Parties or their authorized 

representatives. · 

IN WITNESS WHEREOF, and intending to be legally bound hereby, the Parties 

have executed this Settlement Agreement as ofthe date set forth in the opening paragraph 

ofthis Settlement Agreement. 

For: 	 Federal Deposit Insurance 

Corporation as Receiver 

for IndyMac Bank, F.S.B. 

(b){6) 

... B~'-------::--------1 

Name: le i.s.le.-A. S • G.;~ 

Title: cd u IU •• l 

Date: 1 w-21- ll 

For: 	 Luxury Mortgage Corporation 

By.___________________ 

Name: ___________________ 

Title:_____~----

Date:___________ 

S£1TLEMENT AGREEMENT & OPTION FOR RELEASE 

Page9of 10 
continuing waiver unless specifically stated therein, and the written waiver shall 

operate only as to the specific tenn or condition waived, and not for the future or as to 

any other act than that specifically waived. 

1.36 Headings. The headings ofparagraphs herein are intended solely for 

the convenience ofreference and shall not control the meaning or interpretation ofany 

ofthe provisions ofthis Settlement Agreement. 

1.37 Subsequent Agreements. The Parties agree that, upon the reasonable 

request ofthe other Party, they shall execute, acknowledge, and deliver any additional 

instruments or documents that may reasonably be required to carry out the intentions of 

this Settlement Agreement, including such instruments as may be required by the laws 

ofany jurisdiction, now in effect or hereinafter enacted, that may affect the rights ofthe 

Parties as between themselves or others with respect to their rights and obligations 

created by this Settlement Agreement. 

1.38 Entire Agreement. The Parties hereto further agree and promise that 

this Settlement Agreement sets forth the entire agreement between and among the 

Parties with respect to the repurchase and/or indemnification obligations in connection 

with the LOANS, and fully supersedes any and all prior negotiations, agreements or 

understandings made between or among the Parties. This Settlement Agreement shall 

not be modified except in a writing signed by the Parties or their authorized 

representatives. 

IN WITNESS WHEREOF, and intending to be legally bound hereby, the Parties 

have executed this Settlement Agreement as ofthe date set forth in the opening paragraph 

ofthis Settlement Agreement. 

For: 

(b)(6) 

By: 

Name: 

Title: 

Federal Deposit Insurance For: Luxury Mortgage Corporation 

Corporation as Receiver 

for IndyMac Bank, F.S.B. 

UB~ 

Name: o~,..~~ 1\dgMV 

Title: c.£0 

Date: Date: 1Lz::t LII 

SEffiEMENT AGREEMENT&. OPTION FOR RELEASE 

Pngc9ofl0 
(b)(6) 

By: By: ~---.--------------_J --------------------­

Name: Maurice Wainer Name: John R. Tate 

Title: Counsel for Plaintiff, Federal . Title: Counsel for Defendant Luxury 

Deposit Insurance Corporation as Mortgage Corporation 

Receiver for IndyMac Bank, F.S.B. 

Da1e: (&\,... 24 Date:_________________ '2.Q \ l 

SETILEMENT AGREEMENT & OPTION FOR RELEASE 


Page IOotiO 

(b)(6) 

By:_________ 

Name: Maurice Wainer 

Tille: Counsel for Plaintiff, Federal 

Deposit Insurance Corporation as 

Receiver for lndyMac Bank, F.S.B. 

Date:___________ 

Natf'ie: John R. Tate 

Title: Counsel for Defendant Luxury 

Mortgage Corporation 

Date: :stp!-.;fr, ,2~1( 

SETILEMENT AGREEMENT & OPTION FOR RELEASE 


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