SETTLEMENT AGREEMENTSettlement Agreement • March 20th, 2012 • TMST, Inc. • Real estate investment trusts • Maryland
THIS SETTLEMENT AGREEMENT (“Agreement”) is made and entered into as of the 13th day of February, 2012, by and among Amy Pell (“Ms. Pell”), Deborah Burns (“Ms. Burns”), Larry A. Goldstone (“Mr. Goldstone”), Clarence G. Simmons, III (“Mr. Simmons”), SAF Financial, Inc. (“SAF”), Karen Dempsey (“Ms. Dempsey”), Orrick, Herrington & Sutcliffe, LLP (“Orrick”), Thornburg Mortgage Advisory Corporation (“TMAC”), Garrett Thornburg (“Mr. Thornburg”) (collectively, Ms. Pell, Ms. Burns, Mr. Goldstone, Mr. Simmons, SAF, Ms. Dempsey, Orrick, TMAC and Mr. Thornburg shall be referred to as the “Defendant Parties”), Joel I. Sher, Chapter 11 Trustee (the “Chapter 11 Trustee”) for the bankruptcy estates of TMST, Inc. f/k/a Thornburg Mortgage, Inc., TMST Acquisition Subsidiary, Inc. f/k/a Thornburg Acquisition Subsidiary, Inc., TMST Home Loans, Inc. f/k/a Thornburg Mortgage Home Loans, Inc. and TMST Hedging Strategies, Inc. f/k/a Thornburg Mortgage Hedging Strategies, Inc. (collectively, the “Debtors”), and
