SETTLEMENT AGREEMENTSettlement Agreement • November 2nd, 2006 • Ontario
Contract Type FiledNovember 2nd, 2006 JurisdictionWHEREAS David Humphreys, Jim Kenney, Betty Chou, William G. Armstrong, Rupert Ronald, Barb Montesanto, Bill Ayre and Bill Dunfield, in their capacity as proposed class representatives (the “Plaintiffs”), and Robert James Adams, Select Financial Services Inc., The Estate of Ron Kerfoote, deceased, The Estate of Derwin Trevor Davis, deceased, Shirley Davis, Art Klassen, Willem Termorshuizen, Robert Adourian, Murray Huffman and John Booth, (the “Defendants”), and Murray Huffman (the “Third Party”), (collectively referred to as the “Parties”), enter into this Agreement (hereinafter defined) providing for settlement of the proposed class proceeding described below, subject to the approval of the Ontario Superior Court of Justice (the “Court”);