SETTLEMENT AGREEMENTSettlement Agreement • April 1st, 2019 • Nevada
Contract Type FiledApril 1st, 2019 JurisdictionTHIS SETTLEMENT AGREEMENT (“Agreement”) is made this _ day of April 2019 by and between Gump’s Holdings, LLC, Gump’s Corp., and Gump’s By Mail, Inc. (collectively, “Debtors”), the Official Committee of Unsecured Creditors in the Bankruptcy Cases (as defined below) (the “Committee”), and Sterling Business Credit, LLC (“Sterling”). The Debtors, Committee, and Sterling are each sometimes referred to herein as “Party” and collectively, as “Parties.” All references to Debtors shall include Debtors in their capacities as debtors-in-possession in the Bankruptcy Cases (as hereinafter defined) or as reorganized debtors, or any successor or assignee of the foregoing. This Agreement is predicated upon the following recitals.