SETTLEMENT AGREEMENTSettlement Agreement • February 10th, 2023 • Tennessee
Contract Type FiledFebruary 10th, 2023 JurisdictionThis Settlement Agreement (“Agreement”) is entered into effective as of February 16, 2023 (“Effective Date”) by and between the Society for the Preservation and Encouragement of Barber Shop Quartet Singing in America, Incorporated, d/b/a the Barbershop Harmony Society (“BHS”), all members of the Board of Directors of BHS (“SBOD”), Martin Monson, in his official capacity as Chief Executive Officer and Executive Director of BHS (“Monson”) (BHS, SBOD and Monson being hereafter collectively referred to as the “BHS Parties”) on the one hand, and Harmony Foundation International, Inc., (“HFI”) and its current, former, and putative officers, counsel, and Trustees Gary Plaag, Kendall Williams, Donald A. Laursen, Lynn Weaver, Don Lambert, Sherri Matthews, Mike Moisio, Dan Bell, Jay Bylsma, Christina Lewellen, Perry White, and James Warner (the “HFI Individual Defendants”) (HFI and the HFI Individual Defendants being hereafter collectively referred to as the “HFI Parties”) on the other (each ind