0001013762-10-003102 Sample Contracts

Confidential Settlement Agreement, Mutual Release, and Covenant Not to Sue
Settlement Agreement • December 21st, 2010 • Marine Growth Ventures Inc • Non-operating establishments

This Confidential Settlement Agreement, Mutual Release and Covenant Not to Sue ("Agreement") is entered into this December 17, 2010 by and among FRANK J. ORLANDO ("Orlando"), on the one hand, and MARINE GROWTH VENTURES INC., and its subsidiaries (“MGV”), TITAN GLOBAL HOLDINGS, INC. (“Titan”), FRANK CRIVELLO (“Crivello”), DAVID MARKS (“Marks”), BRYAN CHANCE (“Chance”) and KURT JENSEN (“Jensen”), THE IRREVOCABLE CHILDREN’S TRUST (“ICT”), THE IRREVOCABLE CHILDREN’S TRUST NO. 2 (“ICT2”), CRIVELLO GROUP, LLC (“Crivello Group”), PHOENIX INVESTORS, LLC (“Phoenix”), and FARWELL EQUITY PARTNERS, LLC (“Farwell”) (collectively the “Second Group”) on the other hand.

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