(b)(2) -uttMS N~l· --·--• I 

D~ f / f1wf~ ~q:-~~v-_4 ~received 

·~I >I ~~b.h v I 

CAUSE 2007-47763 

THE FEDERAL DEPOSIT INSURANCE 

CORPORATION, AS RECEIVER FOR 

INDYMAC FEDERAL BANK, FSB 

v. 

COMMONWEAL1H LAND TITLE 

INSURANCE CORPORATION; VISION 

TITLE COMPANY, ET AL 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

.· .· ·: 

·.· 

IN THE DISTRICT COURT OF 

HARRIS COUNTY, TEXAS 

270TH JUDICIAL DISTRICT 

SETTLEMENT AND RELEASE AGREEMENT 

D 

This Settlement and Release Agreement is made by Plaintiff Federal Deposit Insurance 

Corporation, as Receiver for Indy Mac Federal Barik FSB and all of its affiliates, assigns, agents, 

representatives, insurers, lien-holders, subrogees, predecessors and successors in interest and, 

where made expressly applicable, attorneys ("Plaintiff'') in favor of Defendants Secure Financial 

Services, Inc. d/b/a Secure Mortgage Company, Vision Title LLC, Lisa Ross, Lisa Ross & 

Associates, Steadfast Insurance Company, St. Paul Travelers Companies, Inc., and all of their 

partnerships, corporations, officers, directors, shareholders, partners, employees, heirs, affiliates, 

assigns, agents, representatives, insurers, lien-holders, attorneys, and predecessors and 

successors in interest ("Defendants") (collectively the "Parties"). 

WHEREAS, on July 11, 2008, IndyMac Bank, FSB ("IndyMac") filed the above-entitled 

lawsuit, styled IndyMac Bank, FSB and IndyMac Bank, FSB d/b/a Construction Lending 

Corporation of America v. Commonwealth Land Title Insurance Company, Vision Title LL~ 

Boehck Mortgage Company, Jimmy Blacklock, Michael A. Moten, Lisa Ross & Associates, Lisa 

Ross, TX Appraisals, C.D. Pearson & Associates, Kelvin McGowan, Lionel Parker Jr., Raju 

Murjani, and Howard Duplechain, Jr.; in the 270th Judicial District Court of Harris County, 

Texas; Cause No. 2007-47763 (the "Lawsuit"). 

176975.1 
I.·::~ Settlement and ReletiSe Agreenu.. · · 

WHEREAS, after IndyMac filed the lawsuit, the Office of Thrift Supervision ("OTS") 

closed IndyMac, and the FDIC was appointed as IndyMac's receiver. Also on July 11, 2008, a 

new institution, IndyMac· Federal Bank, FSB ("IndyMac Federal"), was chartered, and all of the 

insured deposits and substantially all of the assets of IndyMac were transferred to IndyMac 

Federal. Indy Mac Federal was then placed into conservatorship, and the FDIC was appointed as 

conservator. 

WHEREAS, on December 30, 2008, Plaintiff filed a notice of substitution wherein it 

requested that the FDIC, as conservator for Indy Mac Federal, be substituted as Plaintiff in this 

lawsuit in place of IndyMac. On January 29, 2009, Plaintiff, the FDIC as conservator for 

IndyMac Federal, filed an Amended Original Petltion and Request for Disclosure and became 

the Plaintiff in the Lawsuit 

WHEREAS, On March 19, 2009, the OTS replaced the FDIC as conservator with the 

FDIC as receiver for IndyMac Federal pursuant to 12 U.S.C. § 1464(d)(2)(C) and appointed the 

receiverpursuantto 12 U.S.C. § 1464(d)(2) and 12 U.S.C. §§ 1821(c)(5) and (c)(6)(B). 

WHEREAS, The FDIC as receiver stands in the shoes of Indy Mac Federal to perform all 

functions of the institution in the name of the institution, including prosecution and settlement of 

this Lawsuit. 

WHEREAS, in the Lawsuit, Plaintiff alleged various claims and causes of action against 

. Vision Title LLC, Lisa Ross, and Lisa Ross & Associates arising from their alleged failure to 

exercise ordinary care in two closing transactions ("the Closing Transactions") for residential 

real estate properties located at 1019 Royal Lakes Boulevard, Richmond, Texas and 2205-A 

Nantucket, Houston, Texas (referred to collectively as "the Properties"); 

176975.1 2 
'· . r-·:·· 

'Settlement and Release AgreemL.:~: 

WHEREAS, in the Lawsuit, Plaintiff further alleged that Vision Title LLC, Lisa Ross, 

and Lisa Ross & Associates' alleged failure to exercise ordinary care in the Closi.rig Transactions 

caused Plaintiff damages when the buyers for the Properties defaulted on the loans that Plaintiff 

issued for the purchase of these Properties; 

WHEREAS, Lisa Ross and Lisa Ross & Associates have alleged various claims and 

causes of action against Secure Financial Services, Inc. d/b/a Secure Mortgage Company arising 

from its alleged failure to exercise ordinary care in supervising its employee who sent allegedly 

fraudulent loan documents to the Plaintiff prior to the Closing TransactiollS for the Properties; 

WHEREAS, Vision Title LLC, Lisa Ross, and Lisa Ross & Associates have alleged 

various cross claims and causes of action -~ainst each other arising from the Closing 

Transactions and the Properties, including but not limited to claims for contribution and 

indemnity; 

WHEREAS, Defendants _have denied all of Plaintiffs claims and allegations in their 

entirety, and Vision Title LLC, Lisa Ross, Lisa Ross & Associates, Secure Financial Services, 

Inc. d/b/a Secure Mortgage Company have denied all cross claims, third party claims, and 

allegations that they bring against each other in their entirety; 

WHEREAS, there is considerable doubt, disagreement, and controversy regarding the 

claims and damages alleged by the Parties against each other in the Lawsuit; 

WHEREAS, the Parties desire to enter into a compromise agreement regarding all 

matters related to the Lawsuit, and all unasserted but potential matters of controversy or disputes 

that the Parties brought or could have been brought against each other that relate in any way to 

the facts and/or incidents giving rise to Plaintiff's claims against Defendants in the Lawsuit as 

well as any and all potential future claims, filings and disputes among the Parties that in any way 

arise from or are relate to the Lawsuit; 

176975.1 3 
:'':.:·· ·,! .: 

'Settlement and Release Agreeme:. 

WHEREAS, Defendants expressly deny any liability to Plaintiff or to each other, and the 

consideration described below is not to be construed as an admission ofliability by Defendants; 

Therefore, in consideration of the mutual promises and benefits expressed below, and 

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

acknowledged and confessed, the Parties voluntarily and knowingly execute this Settlement and 

Release Agreement (the "Agreement") with the express intent of extinguishing the herein 

designated rights, claims, and obligations. 

1. Consideration. In consideration of the release and indempity provisions set forth 

in this Agreement and with the understanding by the Parties that no portion of the total sum set 

forth below constitutes exemplary or punitive . damages, Defendants shall tender payments to 

Plaintiff in the total present value amount of THREE HUNDRED lHOUSAND and 00/100 

DOLLARS ($300,000.00) in full and final settlement of all claims and causes of action in the 

Lawsuit (the "Settlement Amount"), out of which Plaintiff is to bear all of its expenses, attorneys' 

fees, costs and liens. The "Settlement Amount" will be paid as follows: 

a. By August 15, 2009, Lisa Ross, Lisa Ross & Associates, and/or their 

insurer shall cause a certified check in the amount of TWO HUNDRED AND FIFTEEN 

THOUSAND AND 00/100 DOLLARS ($215,000.00) to be issued to the Locke Liddell 

Lord & Bissell Trust Account, and delivered to Plaintiff, by and through its attorney of 

record, Robert Mowrey, Locke Lord Bissell & Liddell LLP, 2200 Ross Avenue, Suite 

2200, Dallas, Texas 75201. 

b. Likewise, by August 15, 2009, Vision Title LLC and/or its insurer shall 

cause a certified check in the amount of EIGHTY TIIOUSAND AND 00/100 DOLLARS 

($80,000.00) to be issued to the Locke Lord Bissell & Liddell LLP Trust Account, and 

l7697S.l 4 
.. · SetOement tmd Re/l!ase Agreenri. . 

delivered to Plaintiff, by and through its attorney of record, Robert Mowrey, Locke Lord 

Bissell & Liddell LLP, 2200 Ross Avenue, Suite 2200, Dallas, Texas 75201. 

c. Likewise, by August 30, 2009, Secure Financial Services, Inc. d/b/a 

Secure Mortgage Company shall cause a certified check in the amount of FIVE 

1HOUSAND AND 00/100 DOLLARS ($5,000.00) to be issued to the Locke Lord 

Bissell & Liddell LLP Trust Account, and delivered to Plaintiff, by and through its 

attorney of record, Robert Mowrey, Locke Lord Bissell & Liddell LLP, 2200 Ross 

Avenue, Suite 2200, Dallas, Texas 75201. 

2.1 Full and Final Release. In consideration of, among other things, the Settlement 

Amount, the adequacy and receipt of which is he~eby acknowledged, Plaintiff with the intention 

of binding itself and all of its affiliates, assigns, agents, representatives, conservators, insurers, 

lien-holders, subrogees, attorneys, and predecessors and successors in interest, does hereby 

expressly RELEASE, ACQUIT and FOREVER DISCHARGE Defendant Vision Title LLC, 

Defendant Secure Financial Services, Inc. d/b/a Secure Mortgage Company, Defendant Lisa 

Ross, Defendant Lisa Ross & Associates, and all of their owners, partnerships, corporations, 

officers, directors, shareholders, partners, employees, heirs, affiliates, assigns, agents, 

representatives, insurers, lien-holders, attorneys, and predecessors and successors in interest from 

any and all claims, rights, causes of action, actions, demands and damages of any kind, known or 

unknown, existing or arising in the future, that were asserted or could have been asserted by 

Plaintiff against these Defendants pertaining to the Closing Transactions made the basis of the 

Lawsuit. This Full and Final Release extends to all past, present, and future actions, causes of 

action, claims, demands, damages, costs, loss of services, expenses, compensation, third party 

actions, suits at law or in equity, including claims or suits for contribution and/or indemnity, of 

whatever nature, and all consequential damage on account of, or in any way growing out of, any 

176975.1 5 
, .. ·Settlement and Relelae Agreem...··. 

and all known and unknown injuries or damages arising out of the Closing Transactions for the 

Properties and the events and activities described in the Lawsuit In exchange for the ·abovereferenced consideration, Plaintiff agrees to direct its counsel to stipulate to the dismissal with 

prejudice of the Lawsuit as to these Defendants, each party to bear its own attorneys' fees and 

costs in connection therewith. By this Settlement Agreement, Plaintiff does not release, and 

expressly preserves fully and to the same extent as if the Settlement Agreement had not been 

executed, any claims or causes of action that do not arise from or relate to the Lawsuit, Closing 

Transaction, or the Properties. 

2.2 Defendants Lisa Ross and Lisa Ross & Associates, with the intention of binding 

itself and their attorneys and predecessors anq successors in interest, do hereby expressly 

RELEASE, ACQUIT and FOREVER DISCHARGE Plaintiff, Defendant Secure Financial 

Services, Inc. d/b/a Secure Mortgage Company, Defendant Vision Title LLC, and all of their 

attorneys and predecessors and successors in interest from any and all claims that were asserted 

or could have been asserted by Lisa Ross and Lisa Ross & Associates against these Parties 

pertaining to the Closing Transactions made the basis of the Lawsuit. This Full and Final Release 

extends to all past, present, and future actions, causes of action, claims, demands, damages, 

costs, loss of services, expenses, compensation, third party actions, suits at law or in equity, 

including claims or suits for contribution and/or indemnity, of whatever nature, and all 

consequential damage on account of, or in any way growing out of, any and all known and 

unknown economic injuries or damages arising out of the Closing Transactions for the Properties 

and the events and activities described in the Lawsuit. 

2.3 Defendant Vision Title LLC, with the intention of binding itself and its attorneys 

and predecessors and successors in interest, does hereby expressly RELEASE, ACQUIT and 

FOREVER DISCHARGE Plaintiff, Defendant Secure Financial Services, Inc. d/b/a Secure 

Mortgage Company, Defendant Lisa Ross, Defendant Lisa Ross & Associates, and all of ~eir 

176975.1 6 
·Settlement and Release A.greemt.. • ·. 

attorneys and predecessors and successors in interest from any and all claims that were asserted 

or could have been asserted by Vision Title LLC against these Parties pertaining· to the Closing 

TranSactions made the basis of the Lawsuit. This Full and Final Release extends to all past, 

present, and future· actions, causes of action, claims, ·demands, damages, costs, loss of services, 

expenses, compensation, third party actions, suits at law or in equity, including claims or suits 

for contribution and/or indemnity, of whatever nature, and all consequential damage on account 

of, or in any way growing out of, any and all known and unknown economic injuries or damages 

arising out of the Closing Transactions for the Properties and the events, and activities described 

in the Lawsuit. 

2.4 Defendant Secure Financial Serviqes, Inc. d/b/a Secure Mortgage Company, with 

the intention of binding itself and its attorneys and predecessors and successors in interest, does 

hereby expressly RELEASE, ACQUIT and FOREVER DISCHARGE, Plaintiff, Defendant 

Vision Title LLC, Defendant Lisa Ross, Defendant Lisa Ross & Associates, and all of thek 

attorneys and predecessors and successors in interest from any and all claims that were asserted 

or could have been asserted by Secure Financial Services, Inc. d/b/a Secure Mortgage Company 

against these Parties pertaining to the Closing Transactions made the basis of the Lawsuit. This 

Full and Final Release extends to all past, present, and future actions, causes of action, claims, 

demands, damages, costs, loss of services, expenses, compensation, third party actions, suits at 

law or in equity, including claims or suits for contribution and/or indemnity, of whatever nature, 

and all consequential damage on account of, or in any way growing out of, any and all known 

and unknown economic injuries or damages arising out of the Closing Transactions for the 

Properties and the events and activities described in the Lawsuit. 

2.5 The Parties understand and agree that the payment of the Settlement Amount is 

not to be construed as an admission of liability on the part of any of the Parties, liability therefore 

being expressly denied, but is the compromise and settlement of disputed and unliquidated 

176975.1 7 
.(. -· -. 

· Settlement and Release Agree""-.. .' -·- ... ·- . ·-

claims. The Parties also understand and agree that they are releasing not only the claims 

regarding damages and injuries now known, and regarding any damages, injuries or 

consequential damages that may develop in the future from said existing damages, but also any 

additional damages thereof that may arise, directly or indirectly, from the aforementioned 

Lawsuit, Closing Transactions, and Properties, whether related or unrelated to the presently 

existing damages, even though at the present time said additional damages are completely 

unknown and unsuspected. The Parties further understand and agree that the amount received in 

exchange for this release is accepted not only for the damages that are n!?w, or in the future may 

be claimed to have resulted from the Closing Transactions, but is also accepted to avoid the 

uncertainty, expense, and delay of continuing the :j:,awsuit 

2.6 The release and other agreements made in this Section 2 are, however, 

conditioned upon and shall not be effective until (i) the Parties fully execute and acknowledge 

this Agreement; and (ii) payment of the Settlement Amount has been made. 

3. Representations, Warranties and Acknowledgements. Plaintiff specifically 

warrants and represents that, prior to the execution of this Agreement, it has not assigned, 

mortgaged or transferred to any person or entity, all or any portion of the claims or causes of 

action released herein. Additionally, Plaintiff represents thai all outstanding liens, if any, arising 

by, through or under Plaintiff, have now, or will be, satisfied upon settlement of this matter. 

4. Materiality. The Parties understand and acknowledge that all of the conditions 

and obligations in this Agreement are material. 

5. Binding Effect The Parties understand that this Agreement contains the entire 

agreement between the Parties, and agree that the terms of this Agreement are contractual and 

not a mere recital. In executing the Agreement, the Parties agree that they have not relied,upon 

any statement, representation, or action of any other Party. The Parties understand and agree that 

the covenants contained herein shall be binding upon themselves and, where applicable, their 

176975.1 8 
' . 

·Settlement and Release Agreem",._: · 

respective representatives, agents, conservators, insurers, executors, administrators, successors, 

assigns, subrogees, heirs and their respective attorney~. 

' 6. Invalidity. In the event that any one or more of the provisions of this Agreement 

shall, for any reason, be held invalid, illegal, or unenforceable in any respect, it is agreed that 

such invalidity, illegality or unenforceability shall not affect any other provision of this 

Agreement. 

7. Governing Law. The laws of the State of Texas shall govern the validity, effect 

and construction of this Agreement. 

8. Amendment. This Agreement may not be amended, modified, waived or 

terminated orally or discharged unless by a wri~g signed by all parties to be bound to such 

amendment or modification. 

9. Construction of Agreement. It is intended that this Agreement shall be 

comprehensive in nature and shall be construed liberally to effect its purposes. 

10. Headings. Article and Section headings used in this Agreement are for 

convenience only and shall not affect the construction. 

11.1 Warranty of Understanding. Plaintiff has read this Agreement and has had the 

terms explained to it by Plaintiff's attorney, and warrants that Plaintiff understands all of the 

terms contained in same. Plaintiff further warrants that the Plaintiff's representative that signs 

the Agreement is of legal age, sound mind, legally competent, and expressly authorized by the 

Plaintiff to execute this Agreement, and that this Agreement is executed voluntarily, without 

duress, and with full knowledge of its significance after consultation with counsel. It is 

specifically agreed and understood that no agent or representative of Defendants, nor anyone else 

acting on their behalf, have made any promises or representations regarding this case and 

settlement which are not expressly stated in this Agreement. 

176975.1 9 
· Settlement and llJ!lease Agreemi. ·. 

11.2 It is ~ly understood by the Parties that this Agreement is made in full 

compromise, resolution and settlement of disputed claims, and that such full compromise, 

resolution and settlement and this Agreement shall not be taken as an admission of liability of 

any kind or character by any such party, but rather such liability is expressly denied. 

11.3 This Agreement is executed and shall be binding upon Parties from and after the 

date of the acknowledgements below. 

12. Multiple Counterparts. 1bis Agreement is executed by the Parties hereto in 

multiple originals, any of which shall constitute an original agreement 

176975.1 

. I 

[This space is left intentionally blank so that the Acknowledgements 

and notarized signatures ofthe Parties may follow on Pages 11-14] 

10 
(b)(6) 

Settlement and Release Agreement 

ACKNOWLEDGEMENT 

I am an authorized representative of The Federal Deposit Insurance Corporation, as 

Receiver for IndyMac Federal Bank FSB. I have read the foregoing Full and Final Settlement 

and Release Agreement, Wlderstand its terms and understand that by signing below, The Federal 

Deposit Insurance Corporation, as Receiver for lndyMac Federal Bank FSB hereby gives up any 

right to file or prosecute claims against Vision Title LLC, Lisa Ross, Lisa Ross & Associates, 

Steadfast Insurance Company, St. Paul Travelers Companies, Inc., and Secure Financial 

Services, Inc. d/b/a Secure Mortgage Company relating to the Lawsuit, th..e Closing Transactions, 

or the Properties; any and all claims that were or might have been brought against these Parties 

in connection with the facts and/or incidents .upon which The Federal Deposit Insurance 

Corporation, as Receiver for IndyMac Federal Bank FSB bases its claims in the Lawsuit; as well 

as any and all potential future claims, filings and disputes among the Parties that arose during the 

pendency of this Lawsuit and that relate in any way to the Lawsuit, the Closing Transactions, or 

the Properties. 

~y: I.. . ..... PrinteCTName: :Joe ll- s. Dv,.JCAN 

Authorized Representative of Federal Deposit Insurance 

Corp., as Receiver for IndyMac Federal Bank FSB 

§ 

§ 

§ 

This instrument was before me on this the __ day of 

--------- 2009, by , authorized representative of The 

Federal Deposit Insurance Corporation, as Rec · r for lndyMac Federal Bank FSB. 

Printed Name: 

Commission Expires: --------

176975.1 11 
CALIFORNIA ALL-PURPOSE ACKNOWLEDGMENT 

State,of California 

Countyof 

On f/ :>£'/ ;;HJZ)f 

~ 

before me, 

personally::::.,.: eft S. 

Place Nolary Seal Above 

~personally known to me 

IJ {or proved to me on the basi~ of satisfactory evidence) 

to be the personfs]whose nam$}-islafe subscribed to the 

within instrument and acknowledged to me that 

he!shetthey executed the same in hisA:leFitt:leir authorized 

capac'ityfie¢ and that by hislherAI:leir signatureW-on the 

instrument the person~ or the entity upon behalf of 

which the person(st-acted, executed the instrument. 

WITNESS my hand and official seal. 

j_L(b-)-(S-)~------~~Mn~alumre~olrnN~olamw~F~Db~&e----------~l_ ---------------------OPTIONAL------------------------

Though the information below is not required by law, it may prove valuable to persons relying on the document 

Descriptiona;;:~::~:~n~r :"""'M=~¥fj;~his form to:;J:r~~doc1 enr . . 

Title or Type of Document: ~ ~ 

OocumentDato: f/n~ ~~-1/(/'f} Signer(s) Other Than Named Above: _ _:;)/._~_:,1;:_£ __ ~_--'----------------

Capacity(les) Clai 

Signer's Name: --f-#'!.lrl-~ri--..P:.L.«:LJt"'""<C...J'--­

l J Individual 

Corporate · er - Title(s): 

! : Partner - I I Limited !J General 

; ~ Attorney in Fact 

I I Trustee 

Signer's Name: 

i _;Individual 

1...1 Corporate Officer - Title(s): --"7"'-'-------

1 .J Partner - : i Limited 

: J Atlorney in Fact 

!_;Trustee 

l .I Guardian or Con 

U Other: ---7'<----------
(b)(6) 

(b)(6) 

SEP-03-2009 12:24 VISION. TITLE t·-·--··· 7139794874 ~ ; .. 

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. 

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ACKNOWLEDGEMENT 

l am an authorized representative of Vision Title LLC. I have read the foregoing Full Wld 

Pin:~l Settlement and Relea.,;e Agreement, u-nderstand its terms and unden;tand that by si&nirig 

below, Vision Title LLC hereby gives up any tight to file or prosecute claims against The 

Federal DeposiT Insurance Corporation, a.s Receiver for lndyMac Federal Bank FSB, Lisa Ross, 

Lisa Ross & Associates, Steadfast Insurance Company, and Secure Fina.nc:ial Services, Inc. d/b/a 

Secure Mortgage Comp1111y relating to the Lawsuit, the Closing Transactions, or the Properties; 

tJ.n)' ~11tl !Ill claim:~ that wete or might have been brought against these Pe.tties in connection with 

the facts and/or incidents upon whleh The Federal Deposit Insurance Corporation, as Receiver . •' 

for IndyMac Federo.l Bnnl{ FSB nndfor Vision Title LLC bll.6es its claims in the Lawsuit; as well 

as any and all potential future claims, filing& and disputes among the Parties that arose dwing th~ 

pendency of this U. wsuit md thAt relate in any way to the Lawsuit, the Closing Transactions, or 

the Properties. Additionally, I certify that I understand the ir:tdemnities and/or warranties that I 

. have made in this Set!lement&nd Re!J=:""'~ ·-DT-~e_m_e_~ n-t-~ ________ _j...j_· -

STATE OF TEXAS 

COUNTY OF ;/t9R/?/ :i 

Printed Name: CHillfLP..5 /1, BIX'L.cf<\ 

Authorized Representative ofVisitm Title L!.C 

§ 

§ 

§ 

This instrument wa.~ acknowledged before me on this the 3 day of 

5e'"PTC'MI!£R 2009, byC7'.4 , authorized representative of Vision 

__ Title LLC. __ _ 

Printed N11me: Mfl&t LV} A. Au,.t...E N 

Commission Expires: . 1)':...~-IO 

17697!.1 12 

P.13 
(b)(6) 

(b)(6) 

. 10/22/2~09 14:29 

~ 

71:37397476 ROSS ASSOC AND UISIO PAGE 14/29 

~. 
(b)(6) 

(b)(6) 

· Settlemenl and Release Agrel!l&. . 

ACKNOWLEDGEMENT 

I am an authorized representative of Secure Financial Services, Inc. d/b/a Secure 

Mortgage Company. I have read the foregoing Full and Final Settlement and Release 

Agreement, understand its terms and understand that by signing below, Secure Financial 

Services, Inc. d/b/a Secure Mortgage Company hereby gives up any right to file or prosecute 

claims against The Federal Deposit Insurance Corporation, as Receiver for IndyMac Federal 

Bank FSB, Vision Title LLC, Steadfast Insurance Company, St. Paul Travelers Companies, Inc., 

Lisa Ross, and/or Lisa Ross & Associates relating to the Lawsuit, the Closing Transactions, or 

the Properties; any and all claims that were or might have been brought against these Parties in 

connection with. the facts and/or incidents upon which The Federal Deposit Insurance 

Corporation, as Receiver for IndyMac Federal Bank FSB bases its claims in the Lawsuit; as well 

as any and all potential future claims, filings and disputes among the Parties that arose during the 

pendency of this Lawsuit and that relate in any way to the Lawsuit, the Closing Transactions, or 

the Properties. Additionally, I certify that I understand the indemnities and/or warranties that I 

have made in this Set11ement and Rei: . ...,A-'=

1 

~gr:~e=em=en=:t=. ==~----=---....L--­ PrintedName: ~\~91.'-'- \.....G..~'-~ 

Authorized Representative of Secure Financial Services, 

Inc. d/b/a Secure Mortgage Company 

STATE OF TEXAS § 

COUNTY OF HARRIS ~ o_t 

was acknowled ed thec2_}! day of 

..J..,J,.1.4-.I<~L..I-l..F>'~~- 2009, by .:...m....:......:...i~C.::!...li.IIJ......I.......;,...~~t!.~;:-atJrt:h{lll;i,zJ~renJ~sentative of Secure 

al Services, Inc. d/b/a Secure Mortg;~illrunnatJllL __ __r_::=-----\ 

176975.1 14