0001144204-08-065711 Sample Contracts

SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Settlement Agreement • November 19th, 2008 • Blue Holdings, Inc. • Apparel & other finishd prods of fabrics & similar matl

THIS SETTLEMENT AGREEMENT AND MUTUAL RELEASE (this “Agreement”) is made and entered into as of this 23rd day of September, 2008 (the “Execution Date”), by and among Paul Guez and Elizabeth Guez (collectively the “Guezes”), The Paul and Beth Guez Living Trust (the “Trust”), Blue Concept, LLC, a California limited liability company (“Blue Concept”), Taverniti Holdings, LLC, a California limited liability company (“Taverniti Holdings”), Yanuk Jeans, LLC, a California limited liability company (“Yanuk Jeans” and together with the Guezes, the Trust, Blue Concept and Taverniti Holdings, the “Guez Parties”), and Blue Holdings, Inc., a Nevada corporation (together with any and all of its subsidiaries as appropriate, the “Company”).

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