SETTLEMENT AND RELEASE AGREEMENTSettlement Agreement • July 1st, 2019
Contract Type FiledJuly 1st, 2019This Settlement and Release Agreement (the “Agreement”) is entered into as of the 24th day of May, 2019, by and between (i) Derek Pierce, in his capacity as the court-appointed receiver (the “Receiver”) in that certain civil action styled S.E.C. v. Edwards, et al., No. 17-393 (D.N.J. Jan. 20, 2017) (the “SEC Receivership Case”) and as assignee of certain claims (as described more fully below), (ii) Carr, Riggs & Ingram, LLC (“CRI”), (iii) Wink Laney (“Laney”), (iv) Russ Frederick (“Frederick” and, together with CRI and Laney, the “CRI Parties”), (v) BOKF, National Association d/b/a Bank of Oklahoma, in its capacity as Indenture Trustee for the certain Bonds (as described more fully below) (“Trustee BOKF”), (vi) UMB Bank, N.A., in its capacity as Indenture Trustee for the certain Bonds (as described more fully below) (“Trustee UMB”), and (vii) U.S. Bank, National Association, in its capacity as Indenture Trustee for the certain Bonds (as described more fully below) (“Trustee U.S. Bank”