SETTLEMENT AGREEMENT AND GENERAL RELEASESettlement Agreement and General Release • February 14th, 2013 • Trans-Pacific Aerospace Company, Inc. • Crude petroleum & natural gas • California
THIS SETTLEMENT AGREEMENT AND GENERAL RELEASE (“Agreement”) is made and entered into as of January 30, 2013, by and among Harbin Aerospace Company, LLC, a Nevada limited liability company (“Harbin”), Trans-Pacific Aerospace Company, Inc., a Nevada corporation (“TPAC”, together with Harbin, “Plaintiffs” and each individually a “Plaintiff”), Monarch Bay Associates, LLC, a California limited liability company (“Monarch”), Cardiff Partners, LLC, a California limited liability company (“Cardiff”), David Walters (“Walters”), Keith Moore (“Moore”), Matthew Szot (“Szot”, together with Monarch, Cardiff, Walters, and Moore, the “Defendants” and each individually a “Defendant”), William McKay, an individual (“W.McKay”), Nikki McKay, an individual (“N.McKay”), and Theodora Kobal, an individual (“Kobal”, together with W.McKay and N. McKay, the “Other Parties”). Plaintiffs, Defendants, and the Other Parties are collectively referred to as the “Parties.”
