Exhibit “B*
RELEASE

Subject to full performance of the obligations and representations and warranties
set forth in the Proposal, and effective upon the receipt and clearing of the payment
referred to in paragraph 4 of the Proposal, so that good and clear funds in the ammount
agreed to are actually received by Plaintiff, Plaintiff, for itself and for each and every one
of its current and former officers, directors, joint venturers, partners, employees, agents,
servants, administrators, executors, predecessors, successors, subsidiaries, parents,
affiliates, attorneys, insurers, representatives and assigns, conservators and/or receivers,
and all persons or entities acting by, through, under, for, on behalf of, or in concert with
them, past or present, fully and forever releases, acquits and discharges Defendant and its
respective current and former officers, directors, joint venfurers, partners, employees,
agents, servants, administrators, executors, predecessors, successors, subsidiaries,
parents, affiliates, attorneys, insurers, representatives and assigns, conservators and/or
receivers, and all persons or entities acting by, through, under, for, on behalf of, or in
concert with them (the Releasees), past or present, jointly and severally, from and against
any and all rights, claims, debts, demands, acts, agreements, liabilities, obligations,
damages, costs, fees (including, without limitation, thase of attorneys}, expenses, actions
and/or causes of action of every nature, character and description, or causes of liability,
rights and offset rights, whether at law or im equity, whether known or unknown,
suspected or unsuspected, asserted or unasserted, including without limitation mjunctive
or equitable reef, any award of actual, consequential, meidental, liquidated, or other
types or categories of damages, any award of punitive or exemplary damages, any claims
for attorneys’ fees, costs or expenses of Htigation and any other type of relief which
Plaintiff has, may have or might have against Defendant, the Releasees, or any of them,
pertaining to the Action, and any and all facts, occurrences and transactions alleged in the
Action, provided, however, that this release is not a general release but is expressly and
specifically limited to Action, and any and all facts, occurrences and transactions alleged
in the Action, and is not intended nor shall it be deemed to release any other claims,
demands, causes of actions, debts, obligations, losses damages, liabilities, casts,
expenses, attorneys’ fees, penalties, compensation, right to indemnity and/or demands as
to any other matters that Plaintiff may have or might have against Defendant or the
Releasees, or any of them, including without limitation any other claims, demands or
actions regarding any other matters.

Notwithstanding any other provision contained herein, Plaintiff does not release,
and expressly preserves fully and to the same extent as if the Release had not been
executed, any claims or causes of action: (a) against Defendant that do not arise from or
relate to any and all facts, occurrences and transactions alleged in the Action; and (b)
arising from the transaction at issue in the Action against any other transaction participant
besides Defendant.

Signature and Notary Blocks Follaw


Exhibie "A"

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION

CASE NO. 10-21197-CIV- HUCK/O'SULLIVAN

FEDERAL DEPOSIT INSURANCE
CORPORATION, AS RECEIVER FOR
INDYMAC BANK, FSB,

Plaintiff,
ve
ECONO APPRAISAL INC., ROBERTO
RODRIGUEZ, LANCE MOYSE, and
ATTORNEYS’ TITLE INSURANCE
FUND, INC.,

Defendantss.

JOINT STIPULATION FOR DISMISSAL WITH PREJUDICE
Plaintiff Federal Deposit Insurance Corporation, as Receiver for IndyMac Bank,
FSB (Plaintiff), and defendant Attorneys’ Title Insurance Fund, Inc., pursuant to Federal
Rule of Civil Procedure 41, stipulate that the court may enter an order without further
notice or hearing to dismiss this case with prejudice by and between Plaintiff and only
defendant Attomeys' Title Insurance Fund, Inc.. with each party te bear its own costs and
attorneys’ fees.

Date: ws 2011


Dated: —~ 2. 201! FEDERAL DEPOSIT INSURANCE
CORPORATION, AS RECEIVER FOR
INDYMAC BANK, F.S.B.

ay. (b)(6)
Richa S GiT

te: Clow eee |



IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION

CASE NO. 10-21197-CIV- HUCK/O'SULLIVAN

FEDERAL DEPOSIT INSURANCE
CORPORATION, AS RECEIVER FOR
INDYMAC BANK, FSB,

Plaintiff,
ve
ECONO APPRAISAL INC., ROBERTO
RODRIGUEZ, LANCE MOYSE, and.
ATTORNEYS’ TITLE INSURANCE
FUND, INC.,

Defendants.
i

PLAINTIFF'S PROPOSAL FOR SETTLEMENT TO DEFENDANT
ATTORNEYS’ TITLE INSURANCE FUND, INC,

Plaintiff, Federal Deposit Insurance Corporation, as Receiver for Indymac Bank,
FSB (Plaintiff}, pursuant to FLA. STAT. § 768.79, serves this proposal for settlement (the
Proposal) on defendant Attorneys’ Title Insurance Fund, Inc. (Defendant). The Proposal
must be accepted in writing within thirty (30) days after service ar it shall be deemed
rejected. The Praposal is as follows:

i. Party Making Proposal: Plaintiff.

2. Party te Whom the Preposal is Being Made: Defendant.

3. Claims the Proposal Attempts to Resolve: All issues and claims

asserted, and which could have been asserted, by and between Plaintiff and Defendant in

this, the above-styled action (the Action).


Exhibie *C?
RELEASE

Subject to fall performance of the obligations and represeritations and warranties
set forth in the Proposal, and effective simultaneously with the Release. executed: by
Plaintif’ at Exhibi “B” above, Defendant, on behalf of ivelf individually and foreach
and every one of iis respective current and former officers, directors, joint ventirers,
partners, employees, agents, servants, administrators, executors, predecessors, suceessors,
subsidiaries, parents, affiliates, attorneys, insurers, representatives and assigns,
conservators and/or-receivers, and all persons or-entities acting by, through, under, for, on
bebalf af, or in concert with them, past or present, fully and forever release, acquit and
discharge Plaintiff and its current and former officers, directors, joint venturers, partners,
empleyees, agents, servants, administrators, executors, predecdssors, susceisors,
subsidiaries, parents, affiliates, attomeys, insurers, representatives and assigns, and all
persons or entities acting by, through, under, for, on belialf of, or in concert with ther,
past or present, jointly and severally, from and against any and all rights, clanms, debts,
demands, acts, agreements, Habilities, obligations, darnages, costs, fees Cncluding,
without Hritation, those of attormeys), expenses, actions aad/or causes of action of every
nature, character and description, or causes of liability, rights and offset rights, whether at
law or in equity, whetlier known of unknown, siwpected or unsuspected, asserted or
unasserted, including without limitation injunctive or equitable relief, any award of
actual, consequential, incidental, liquidated, or other types or categuries of damages, any
award of positive orexemplary damages, any claims for attorneys’ fires, costs or-expenses
af litigation and any other type of relief which Defendant may have or might have against
Plaintiff pertaining to any ond all facts, oveurrenves and transactions alleged in the
Action, provided, however, that this release is not a general release but is-expressly and
specifically limited to any and all facts, occurrences and transactions alleged in the
Action, arid is :not intended sor shall it be deemed to release any other lainws, demands,
causes of actions, debts, obligations, losses damages, lsbilities, costs, expenies,
attorneys’ fees, penalties, compensation. right to indemnity and/or: dematids as to. any
other matters that Defendant-may have or might have against Plaintiff, including without
limitation any other claims, demands or actions regarding any other tnatter,

Dated: Vesey a4 2011 Attomeys' Tide Insurance Fund, Inc.
By: (b)(6)
ee
lis: Qiet C1 hick



4. Total Amount of Proposal: Plaintiff proposes to resolve the Action in
exchange for payment to Plaintiff from Defendant in the amount of Twenty Thousand
Dollars and Zero Cents ($20,600.00), inclusive of all damages, attorney's fees, costs, and
prejudgment interest.

3, Non-monetary Terms of Proposal, if any: Upon Defendant's acceptance
of the Proposal, Plaintiff shall dismiss the Action with prejudice as against Defendant in
the form attached hereto as Exhibit "A." The Parties shall execute mutual releases of all
issues and claims asserted amongst them in the Action, copies of which are attached
hereto as Exhibits “B" and "C", respectively.

6. Punitive Damages: There are no claims for punitive damages pending in
the Action.

7. Filing of Proposal: This Proposal is not being filed with the Court, unless
and until it becomes necessary to enforce the provisions of FLA. STAT. § 768.79,

Dated: May 13, 2011.

ésf Justin B. Hekkanen
William P. Heller
Florida Bar Number. 987263

Justin E. Hekkanen
Florida Bar Number: 33712

AKERMAN SENTERFITT

350 East Las Olas Blvd., Suite 1600
Fort Lauderdale, FL 33301
Telephone: 954.759.8945
Facsimile: 954.463.2224

Counsel for Federal Deposit Insurance
Corporation, as Receiver for IndyMac
Bank, FSB


CERTIFICATE OF SERVICE

\ hereby certify that a true and correct copy of the foregoing was served via

facsimile, e-mail, and U.S. mail on May 13, 2011 on counsel or parties of record noted on
the Service List below.

ésf Justin £ Hekkanen
Attorney

SERVICE LIST

Aaron Christopher Wong
Coben Fox

261 S Biseayne Boulevard
Suite 850

Miami, FL 33131-2310
T3205) 702-3000

— 702-3030 om

Counsel for Attorneys’ Title Insurance
Fund, fic.

ist Justin E. Hekkanen
Aitomey

we