AGREEMENTAgreement • December 14th, 2005 • Sinofresh Healthcare Inc • Pharmaceutical preparations
SinoFresh HealthCare, Inc. (“The Corporation”) hereby makes the following agreement with the law firm of David. B. Haber, P.A. (“Firm”) regarding any and all claims for attorney’s fees and costs as Plaintiffs’ Counsel in the U.S. District Court in the Middle District of Florida which shareholders’ derivative action and malpractice action, Case No. 8:04-CV-490-T-30MSS, is filed (“Litigation”).
SETTLEMENT AGREEMENT AND MUTUAL RELEASES (the “agreement”)Settlement Agreement and Mutual Releases • December 14th, 2005 • Sinofresh Healthcare Inc • Pharmaceutical preparations
THIS SETTLEMENT AGREEMENT AND MUTUAL RELEASE is made this 7th day of December, 2005 by and among MICHAEL HAWKINS, RUSSELL WAGGONER, STEVE BANNON, DAVID OTTO, TOM G. AMON, EVERETT C. SETSER, KENNETH BADOLATO, DR. DAVID W. BADOLATO, GAMI, LLC, AND CROWN IV HOLDINGS, INC. (collectively, the “Named Plaintiffs”), SINOFRESH HEALTHCARE, INC. (the “Corporation”), the OTTO LAW GROUP, PLLC (the “Otto Law Group”), CHARLES FUST, STACEY MALONEY FUST, ROBERT DUPONT (the “Individual Defendants”), DON FEE, KEN HALL, TERRY TURNER, HARVEY HENDLER, CINCO HABANEROS, INC., DIESPITER LTDA, BOSTON MEDICAL INVESTORS LLC, SPARTACUS HEALTHCARE PARTNERS IV, BIG GAMES HOLDINGS INC. (the “Absent Named Plaintiffs”), and RANDOLPH FIELDS, GREENBERG TRAURIG P.A. (together, “GT”) (collectively, the “Parties”).
