SETTLEMENT AND RELEASE AGREEMENT 

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

the following undersigned parties: Federal Deposit Insurance Corporation as Receiver for Sun 

West Bank ("FDIC-R"); Jackie K. Delancy, Larry E. Carter, Mark A. Stout, Kenneth Templeton, 

John Shively, Steven C. Kalb, Jerome F. Snyder, Hugh Templeton, and Rick Dreschler 

(collectively the "Settling Defendants"); and Progressive Casualty Insurance Company 

("Progressive") (individually, the FDIC-R, the Seuling Defendants, and Progressive may be 

referred to herein as "Party" and collectively as the "Parties"). 

RECITALS 

WHEREAS: 

Prior to May 28, 2010, Sun West Bank ("Bank") was a depository institution organized 

and existing under the laws of the United States of America; 

On May 28, 2010, the Nevada Department of Business and Industry, Financial 

Institutions Division closed the Bank, and, pursuant to 12 U.S.C. § 1R21(c), the Federal Deposit 

Insurance Cmvoration was appointed receiver. In accordance with 12 U.S.C. § 182l(d), FDIC-R 

succeeded to all rights, titles, powers, and privileges of the Bank, including those with respect to 

its assets; 

Among the assets to which the FDIC-R succeeded were all of the Bank's claims, 

demands, and causes of action against its former directors, officers, and employees arising hom 

the performance, nonperformance, and manner of performance of their respective functions, 

duties and acts as directors, officers, and employees of the Bank; 

On May 24,2013, 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 District of 

Nevada in FDIC-R v. Delaney, era/., No. 2: 13-cv-00924-JCM-VCF ("D&O Action"). The 

Settling Defendants have denied, and continue to deny, liability in the D&O Action; 

Progressive issued a director and officer liability policy numbcre~ j{thc (p)(4.J 

''Policy") under which the directors and officers of the Bank were insureds according to the 

terms, provisions, and conditions of the Policy. The Settling Defendants asserted claims for 

coverage under the Policy. Insurer has reserved its rights to deny coverage under the Policy for 

claims asserted by the FDIC-R against the Settling Defendants. Additionally, Insurer filed a 

declaratory judgment action against Settling Defendants seeking a declaration of its rights and 

obligations under the Policy with regard to the claims asserted by the FDIC-R against them. 

That action is now pending before the United States District Court for the District of Nevada in 

Progressive Casualty Insurance Company v. Delaney. el a/., No. 2:11-cv-00678-LRH-PAL 

("Coverage Action"). The FDIC-R intervened as an additional defendant in the Coverage 

Action; and 

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

avoid the uncertainty and expense of further litigation. 

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 FDIC-R 

A. As an essential covenant and condition to this Agreement, on or before the 30111 

calendar day following the date this Agreement is executed by all the Parties ("Payment Date"), 

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Progressive, on behalf of Progressive and the Settling Defendants, agrees to pay to the FDIC-R 

the sum of ONE MILLION SEVEN HUNDRED THOUSAND DOLLARS (S I ,700,000) ("the 

Settlement Payment"). 

B. The Settlement Payment sha11 be delivered to FDIC-R by direct wire transfer into 

an account designated by FDIC-R by notice to the attorneys for Progressive. Such notice, along 

with an executed IRS Form W-9 for the designated account, shall be provided no fewer than ten 

(I 0) days before the Payment Date. 

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

Payment Date, then the FDIC-R, in its sole discretion, shall have the right at any time prior to 

receipt of the Settlement Payment in fu11 (including any interest accruing pursuant to Section 

I(C)( l) of this Agreement) to: 

I. Extend the period of time for the Settlement Payment, including interest, 

which shall accrue after the Payment Date through the actual date of payment at a rate 

calculated in accordance with 26 U.S.C. § 662l(a)(2); 

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

Progressive agree to jurisdiction in the United States District Court for the District of 

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

enforcing the terms of this Agreement; 

3. Terminate the Agreement, move to vacate any dismissal order (to which 

motion or stipulation to vacate such dismissal order the Settling Defendants and 

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

Settling Defendants and Progressive further covenant and agree to waive and not assert 

any objections, defenses, claims, or counterclaims that (i) did not exist or were otherwise 

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unavailable as of the date this Agreement was fully executed, and (ii) which later came 

into existence and became available only because the FDIC-R chose to enter into this 

Agreement. Specifically included within this waiver is any defense based on any statute 

of limitations that would bar any of the FDIC-R's claims; 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 Settlement Payment or 

acceptance of a portion of the Settlement Payment shall not prejudice the FDIC-R · s rights to take 

any of the actions set forth in Section I.C.2 through I.C.4 at any time prior to receipt of 

Settlement Payment (including any interest accruing pursuant to Section I(C)(l) of this 

Agreement) in full. 

SECTION II: Stipulation and Dismissal 

Within ten (I 0) business days after the latter of (I) full execution of this Agreement by all 

of the Parties, or (2) receipt of the Settlement Payment, plus any interest accruing pursuant to 

Section l(C)( l) of this Agreement, the FDIC-R shall file a stipulation of dismissal with prejudice, 

executed by the attorneys for all the Settling Defendants, in the form attached hereto as Exhibit 

A, in the D&O Action. 

Within ten ( 10) business days after the latter of (I) full execution of this Agreement by all 

of the Parties, or (2) receipt of the Settlement Payment, plus any interest accruing pursuant to 

Section I( C)( I) of this Agreement, Progressive shall file a stipulation of dismissal with prejudice, 

executed by the attorneys for all Parties in the form attached hereto as Exhibit B, in the Coverage 

Action. 

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SECTION III: Releases 

A. The FDIC-R's Releases. 

Upon receipt of the 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: 

l. The Settling Defendants and their respective heirs, executors, trustees, trusts, 

administrators, representatives, successors, and assigns from any and al1 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 

manner of performance of the Settling Defendants' respective functions, duties and actions as 

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

action alleged in the D&O Action and the Coverage Action. 

2. Progressive, its parents, subsidiaries, affiliates, and reinsurers, and its and their 

respective employees, officers, directors, agents, representatives, successors, and assigns li·om 

any and al1 claims, demands, obligations, damages, actions and causes of action, direct or 

indirect, in law or in equity, that arise from or relate to the Coverage Action, the D&O Action, 

the Bank, the Policy, or to the performance, nonperformance, or manner of performance 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. As part of 

this release of Progressive, the FDIC-R agrees that any interest it may have under the Policy is 

extinguished. 

3. All former directors, officers, and employees of the Bank other than the Settling 

Defendants (collectively, the "Covered Persons") and their respective heirs, executors, trustees, 

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

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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 

manner of performance of the 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 asserts any claim against the FDIC-R. 

B. The Settling Defendants' Release. 

Effective simultaneously with the release granted in Section lii.A. above, the Settling 

Defendants, on behalf of themselves individually, and their respective heirs, executors, trustees, 

trusts, administrators, agents, representatives, attorneys, successors, and assigns, hereby release 

and discharge: 

I. FDlC-R and its employees, officers, directors, representatives, successors, and 

assigns hom 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 D&O Action, the Bank or to 

the performance, nonperformance, or manner of performance 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 and the Coverage Action. 

2. Progressive, its parents, subsidiaries, affiliates, and reinsurers, and its and their 

respective employees, officers, directors, agents, representatives, attorneys, 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 arise from or relate to the Policy, the D&O Action or 

the Coverage Action. 

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3. Each other and each other's respective heirs, executors, trustees, administrators, 

agents, representatives, insurers, successors, and assigns, from any and all c1aims, demands, 

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

arise from or relate to the D&O Action or the Coverage Action. 

C. Progressive's Release. 

Effective simultaneously with the releases granted in Section III.A. above, Progressive, 

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: 

l. FDIC-R and its employees, officers, directors, agents, 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 arise fi"om or relate to the Coverage Action, the 

D&O Action, the Bank, the Policy, or to the performance, nonperformance, or manner of 

performance 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. Each of the Settling Defendants and their respective heirs, executors, trustees, 

trusts, administrators, agents, representatives, insurers, attorneys, successors, and assigns li·01n 

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 Policy, or that arise fi"om or relate to, 

the performance, nonperformance, or manner of performance of the Settling Defendants' 

respective functions, duties, and action as employees, officers and/or directors of the Bank or any 

other capacity including, without limitation, the causes of action alleged or which could have 

been alleged in the D&O Action, the Coverage Action, or any other legal proceeding. 

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D. Exceptions fi·om Releases by FDIC-R. 

I. Notwithstanding any other provision of this Agreement, the FDIC-R docs 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, 

incurred as the maker, endorser, or guarantor of any promissory note or 

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

institutions, or any other person or entity, including without limitation any such 

claims acquired by FDIC-R as successor in interest to the Bank or any person or 

entity other than Bank; 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 construed 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 if 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 

through the Department of Justice, the United States Attorney's Office for any federal judicial 

district, or any other department 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 court-ordered restitution pursuant to 

8 
the relevant provisions of the Mandatory Victims Restitution Act, 18 U.S.C. §§ 3322 and 3663 

ct. seq., if appropriate. 

SECTION IV: Waiver of Dividends and Proceeds from Litigation 

To the extent, if any, that Settling Defendants arc 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 

distribution upon resolution of the receivership of the Bank 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 Corporation 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: Representations and Acknowledgements 

A. Authorized Signatories. All of the undersigned persons represent and wan·ant that 

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

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

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. 

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SECTION VI: Reasonable Cooperation 

The Parties agree to cooperate in good faith to effectuate a11 the terms 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, 

or any documents necessary to conclude the D&O Action and Coverage Action, and to otherwise 

perform the terms of this Agreement. 

SECTION VII: Other Matters 

A. No Admission of Liability. The undersigned Parties each acknowledge and agree 

that the matters set forth in this Agreement constitute the settlement and compromise or disputed 

claims and defenses, that this Agreement is not an admission or evidence of liability, fault, 

wrongdoing, or infirmity by any of them regarding any claim or defense, and that the Agreement 

shall not be offered or received in evidence by or against any Party except to enforce its terms. 

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

one or more of the Parties and all such counterparts when so executed sha11 together constitute 

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

coumerpart, 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 Nevada. 

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

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

If to the FDIC-R: 

John C. Letteri 

FEDERAL DEPOSIT INSURANCE CORPORATION 

lO 
(b)(6) 

If to Settling Defendants 

PhillipS. Aurbach 

Marquis Aurhach Coffing 

10001 Park Run Drive 

Las Vegas, NV 89145 

•....... 

& 

Kevin D. Hughes 

Linda J. Kim 

2029 Century Park East, Suite 900 

Los Angeles, CA 90067 

(b)(6) ··············································································································································································· 1 ..... ______ __. 

(b)(6) 

(b)(6) 

(Counsel for Kenneth Templeton) 

Kevin R. Stolworthy 

Tracy A. DiFillippo 

Conor P. Flynn 

Armstrong Teasdale, LLP 

3770 Howard Hughes Pkwy., 

Suite 200 

Las Vegas, NV 89169 

(Counsel tor Jackie Delaney) 

Aaron L. Snyder, Esq. 

Law Offices of Aaron L. Snyder 

212 Lessin Lane, Unit A 

Austin, TX 78704 

8628 Scarsdale Drive 

Las Vegas, NV 89117 

1 ........... ______ __. 

(Counsel for Larry Carter, Steven Kalb, Jerome Snyder, Mark 

Stout, and Hugh Templeton) 

II 
(b)(6) 

(b)(6) 

If to Progressive: 

David T. Duncan 

Duncan Law Finn 

6200 Stoncridgc Mall Road, Suite 300 

Pleasanton. CA 94588 

·················· !_····· ...... ____ ____. 

(Counsel for John Shively and Rick Dreschler) 

Lewis K. Loss 

Loss, Judge & Ward, LLP 

1133 2 r' Street, NW 

Wasbjnglon DC 2~036 

l : 

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 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 Parties hereto have caused this Agreement to be executed 

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

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FEDERAL DEPOSIT INSURANCE 

Date: :...~~{-··,·\...·;.: r·---t j l ') ,,· \ <~~ CORPORATION AS RECEIVER FOR SUN ;1- (;.' r- - ! . 

WES'[ BAN lSi 

By:J ...................... l ························· ················································ 

; 

TITLE:.-Counsel 

PRINT NAME: John Letteri 

Date: 

Jackie K. Delaney 

Date: 

Larry E. Carter 

Date: 

Mark A. Stout 

Date: 

Kenneth Templeton 

Date: 

John Shively 

13 
FEDERAL DEPOSIT INSURANCE 

Date: CORPORATION AS RECEIVER FOR SUN 

WEST BANK 

By: 

TITLE: Counsel 

PRINT NAME: John Letteri 

1\ 

2, a,s=' LS: ( ······ ·-··········· .. 

Date: .... 

-

Jackie K. Delaney ....._, 

Date: 

Larry E. Carter 

Date: 

Mark A. Stout 

Date: 

Kenneth Templeton 

Date: 

John Shively 

13 
(b)(~~b.23.2015 05:07-·······PM ... rt=·······=====---------- PAGE. 2/ 2 

FEDERAL DEPOSIT INSURANCE 

CORPORATION AS RBCEIVER FOR SUN 

Da~: -- -~-

WEST BANK 

Dy: ___ -

TITL£: Counsel 

PRlNTNAMB: John Letteri 

. 

Date: - - -·- --

Jackie K. Delancy 

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Larry E. Carter 

Date: .~ -

MKI'k A. Stout 

Dpte: ,_ 

Kenneth Templeton 

1-· 

- Date: -· ___ .. - John Shively 

13 
FEDERAL DEPOSIT INSURANCE 

Date: CORPORATION AS RECEIVER FOR SUN 

WEST BANK 

By: 

TITLE: Counsel 

PRINT NAME: John Letteri 

Date: 

Jackie K. Delaney 

Date: 

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MarkA.St )_ 

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Date: 

Kenneth Templeton 

Date: 

John Shively 

13 

. .. .... , ;,· . . 
fEDERAL DEPOSIT INSURANCE 

Date: COJ~PORATION AS RECEIVER FOR SUN 

WEST BANK 

By: 

TITLE: Counsel 

J>RINT NAME: John Letteri 

... ---.... ----.... 

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Jaokie K. Delaney 

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Larry E. Carter 

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Mat·k A. Stout Jy; 

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Kenneth T~on 

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Date: ·-·······-~·-

John Shively 

13 
Date: _ ______ _ 

FEDERAL DEPOSIT INSURAN~ CORPORATION AS RECEIVER FOR SUN 

WEST BANK 

By: _ ___ __________ ___ 

TITLE: Counsel 

. PRINT NAME: John Lcttcri 

----- ----·--.. ---·--- - ----;------- - -

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Steven C. Kalb 

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Jerome F. Snyder 

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Hugh Templeton 

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Rick Dreschler 

PROGRESSIVE CASUALTY INSURANCE 

Date: COMPANY 

By: 

TITLE: -·· 

PRINT NAME: - -

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Date: ··-·-·····-···- - ·----- -··· 

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14 
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14