Settlement Agreement and Stipulation Sample Contracts

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • February 26th, 2015 • Genufood Energy Enzymes Corp. • Medicinal chemicals & botanical products • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION is dated as of February 19, 2015 by and between Genufood Energy Enzymes Corp. (“Genufood” or the “Company”), a corporation formed under the laws of the State of Nevada, and IBC Funds, LLC (“IBC”), a Nevada Limited Liability Company.

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SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • October 14th, 2020 • Wearable Health Solutions, Inc. • Communications equipment, nec • Maryland

THIS SETTLEMENT AGREEMENT and Stipulation dated as of August , 2020 (“Agreement”) by and between plaintiff Trillium Partners LP (“TRILLIUM”), and defendant Wearable Health Solutions, Inc. (“COMPANY”).

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • April 6th, 2017 • Cherubim Interests, Inc. • Wholesale-groceries & related products • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION is dated as of March __, 2017 by and between Cherubim Interests, Inc. (“CHIT” or the “Company”), a corporation formed under the laws of the State of Nevada, and Northbridge Financial, Inc., (“NBF”), a Delaware Corporation.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • September 22nd, 2014 • Propanc Health Group Corp • Pharmaceutical preparations • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION, dated as of July 18, 2014 (the "Agreement"), by and between plaintiff Tarpon Bay Partners LLC (“TARPON”), and defendant PROPANC HEALTH GROUP CORPORATION (the “Company ”).

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • April 26th, 2021 • Borqs Technologies, Inc. • Services-computer integrated systems design • New York

This SETTLEMENT AGREEMENT AND STIPULATION (this “Agreement”), is dated as of December 14, 2020, by and between plaintiff LMFA Financing, LLC, a Florida limited liability company (the “Creditor”) and defendant Borqs Technologies, Inc., a company incorporated in the British Virgin Islands, with headquarters located at Building B23-A, Universal Business Park No. 10 Jiuxianqiao Road Chaoyang District, Beijing 100015, China (the “Company”).

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • September 10th, 2014 • Worthington Energy, Inc. • Crude petroleum & natural gas • Florida

THIS SETTLEMENT AGREEMENT and Stipulation dated as of April 3, 2014 by and between plaintiff Tarpon Bay Partners LLC (“TARPON”), and defendant Worthington Energy, Inc. (“COMPANY”).

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • September 13th, 2019 • Lifequest World Corp. • Food and kindred products • Maryland

THIS SETTLEMENT AGREEMENT and Stipulation dated as of June 29, 2018 by and between plaintiff ANTEVORTA CAPITAL PARTNERS, LTD. (“ANTEVORTA”), and defendant LIFEQUEST WORLD CORPORATION (“COMPANY”).

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • February 14th, 2014 • Frozen Food Gift Group, Inc • Retail-catalog & mail-order houses • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION dated as of February , 2014 by and between Frozen Food Gift Group, Inc. (“Frozen” or the “Company”), a corporation formed under the laws of the State of Delaware, and IBC Funds, LLC (“IBC”), a Nevada Limited Liability Company.

Contract
Settlement Agreement and Stipulation • October 23rd, 2013 • Urban Ag. Corp • Hazardous waste management • Florida
SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • October 21st, 2016 • Andalay Solar, Inc. • Heating equipment, except electric & warm air furnaces • Florida

THIS SETTLEMENT AGREEMENT and Stipulation, dated as of August 3, 2016 (the "Agreement"), by and between plaintiff Tarpon Bay Partners LLC (“TARPON”), and defendant Andalay Solar, Inc. (the “Company ”).

AMENDMENT TO SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • June 21st, 2018 • Rokk3r Inc. • Services-management consulting services • Nevada

THIS AMENDMENT TO SETTLEMENT AGREEMENT AND STIPULATION (the “Amendment”) is made effective as of June 15, 2018 by and between FIRSTFIRE GLOBAL OPPORTUNITIES FUND, LLC, a Delaware limited liability company (“Creditor”) and ROKK3R INC. (formerly Eight Dragons Company), a Nevada corporation (“Company”). Creditor and the Company may collectively be referred to as the “Parties”.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • March 25th, 2015 • Peer to Peer Network • Services-computer integrated systems design • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION is dated as of March ___, 2015 by and between Peer to Peer Network (“PTOP” or the “Company”), a corporation formed under the laws of the State of Nevada, and IBC Funds, LLC (“IBC”), a Nevada Limited Liability Company. BACKGROUND:

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • February 6th, 2018 • Cherubim Interests, Inc. • Wholesale-groceries & related products • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION is dated as of _____________, 2018 by and between Cherubim Interests, Inc. (“CHIT” or the “Company”), a corporation formed under the laws of the State of Nevada, and Northbridge Financial, Inc., (“NBF”), a Delaware Corporation.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • April 2nd, 2020 • Web Blockchain Media, Inc. • Services-computer integrated systems design • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION is dated as of _______________ by and between Web Blockchain Media, Inc. (“WEBB” or the “Company”), a corporation formed under the laws of the State of Colorado, and Continuation Capital, Inc., (“CCI”), a Delaware Corporation.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • December 2nd, 2016 • MyDx, Inc. • Measuring & controlling devices, nec • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION is dated as of November 29, 2016 by and between MyDx, Inc. (“MYDX” or the “Company”), a corporation formed under the laws of the State of Nevada, and Rockwell Capital Partners, Inc., (“RCP”), a Delaware Corporation.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • January 21st, 2015 • Il2m INTERNATIONAL CORP. • Pharmaceutical preparations • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION is dated as of January ___, 2015 by and between IL2M International Corp. (“IL2M” or the “Company”), a corporation formed under the laws of the State of Nevada, and IBC Funds, LLC (“IBC”), a Nevada Limited Liability Company.

AMENDMENT TO SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • June 9th, 2014 • RestorGenex Corp • Services-amusement & recreation services

THIS AMENDMENT TO THE SETTLEMENT AGREEMENT and Stipulation dated as of June 6, 2014 (“Amendment”) by and between plaintiff ASC Recap LLC (“ASC”), and defendant RestorGenex Corporation (formerly Stratus Media Group, Inc.) (the “Company”).

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • September 10th, 2013 • Pharmagen, Inc. • Metal mining • Florida

THIS SETTLEMENT AGREEMENT and Stipulation dated as of _________, 2013 by and between Pharmagen, Inc. (“Pharmagen” or the “Company”), a corporation formed under the laws of the State of Nevada, and IBC Funds, LLC (“IBC”), a Nevada Limited Liability Company.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • July 28th, 2014 • Seaniemac International, Ltd. • Communications services, nec • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION is dated as of July 17, 2014 by and between Seaniemac International, Ltd. (“SM” or the “Company”), a corporation formed under the laws of the State of Nevada, and IBC Funds, LLC (“IBC”), a Nevada Limited Liability Company.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • October 2nd, 2014 • Epazz Inc • Services-prepackaged software • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION dated as of February __, 2014 by and between Epazz, Inc. (“Epazz” or the “Company”), a corporation formed under the laws of the State of Illinois, and IBC Funds, LLC (“IBC”), a Nevada Limited Liability Company.

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SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • February 2nd, 2010

This Settlement Agreement and Stipulation (the "Agreement") is entered into as of February 2, 2010, between Herbert Williams, Sr. and Patricia Cousar Williams (“Class Representatives”), suing individually and on behalf of the Settlement Classes defined below, and the following entities: Government Employees Insurance Company, GEICO General Insurance Company, GEICO Indemnity Company, and GEICO Casualty Company (collectively “Defendants”).

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • June 9th, 2016 • InCapta, Inc. • Services-video tape rental • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION is dated as of May 31, 2016 by and between InCapta, Inc. (“INCAPTA” or the “Company”), a corporation formed under the laws of the State of Nevada, and Rockwell Capital Partners, Inc., (“RCP”), a Delaware corporation.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • July 28th, 2015 • Elite Data Services, Inc. • Orthopedic, prosthetic & surgical appliances & supplies • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION ("Agreement") is entered into as of July 21st, 2015 (the "Effective Date") by and between ELITE DATA SERVICES INC. f/k/a Dynamic Energy Alliance Corp. ("EDS"), a Florida corporation, on the one hand, and BIRCH FIRST CAPITAL FUND, LLC ("Birch First Capital"), a Delaware limited liability company and BIRCH FIRST ADVISORS, LLC ("Birch Advisors"), a Delaware limited liability company (together with Birch First Capital, "Birch First"), on the other hand. EDS, Birch First, and Birch Advisors are each referred to herein collectively as a "Party" and collectively, the "Parties."

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • September 22nd, 2014 • BioNeutral Group, Inc • Industrial inorganic chemicals • New Jersey

THIS SETTLEMENT AGREEMENT and Stipulation dated as of September 20, 2013 by and between ASC Recap LLC ("ASC"), a limited liability company formed under the laws of the State of Connecticut, with offices in Fairfield County, Connecticut, and Bioneutral Group, Inc., a corporation incorporated under the laws of Nevada, with offices in Newark, New Jersey ("COMPANY").

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • March 10th, 2014 • Andalay Solar, Inc. • Heating equipment, except electric & warm air furnaces • Florida

THIS SETTLEMENT AGREEMENT and Stipulation dated as of February 26, 2014 by and between plaintiff ASC Recap LLC (“ASC”), and defendant Andalay Solar, Inc. (“COMPANY”).

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • September 8th, 2014 • ERF Wireless, Inc. • Communications equipment, nec • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION dated as of January 28, 2014 by and between ERF Wireless, Inc. ("ERF" or the "Company"), a corporation formed under the laws of the State of Nevada, and CP US INCOME GROUP, LLC ("CP US"), a Nevada Limited Liability Company.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • November 22nd, 2016 • Simlatus Corp • Gold and silver ores • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION is dated as of November _, 2016 by and between Simlatus Corporation ("SIML" or the "Company"), a corporation formed under the laws of the State of Nevada, and Rockwell Capital Partners, Inc., ("RCP"), a Delaware Corporation.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • January 13th, 2015 • Alkame Holdings, Inc. • Wholesale-groceries & related products • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION dated as of November 10, 2014 by and between Alkame Holdings, Inc. ("ALKM" or the “Company”), a corporation formed under the laws of the State of Nevada, and EROP Capital LLC ("EROP"), a Florida Limited Liability Corporation.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • July 12th, 2023

This Settlement Agreement and Stipulation (the “Agreement”) is entered into by and between Emily Glaspie (“Class Representative” or “Dr. Glaspie”), on behalf of herself and the Settlement Class defined below, and the National Association of Boards of Pharmacy (“NABP” or “Defendant”). This Agreement is being submitted pursuant to Federal Rule of Civil Procedure 23 and is subject to preliminary and final approval by the Court.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • May 17th, 2022 • ECGI Holdings, Inc. • Florida

THIS SETTLEMENT AGREEMENT and STIPULATION (the “Agreement”) dated as of March 11th 2021, by and between ECGI Holdings, Inc. (“ECG!” or the “Company”), a corporation formed under the laws of the State of Nevada, and EROP Enterprises, LLC (“EROP”), a Florida limited liability corporation.

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • April 17th, 2018 • Rokk3r Inc. • Services-management consulting services • Florida

This SETTLEMENT AGREEMENT and STIPULATION dated as of November 15, 2017 (the “Agreement”) by and between FIRSTFIRE GLOBAL OPPORTUNITIES FUND, LLC, a Delaware limited liability company (“Creditor”) and EIGHT DRAGONS COMPANY, a Nevada Corporation (“Company”).

SETTLEMENT AGREEMENT AND STIPULATION
Settlement Agreement and Stipulation • October 16th, 2018 • Maryland

THIS SETTLEMENT AGREEMENT and Stipulation dated as of October 10, 2018 (“Agreement”) by and between plaintiff One Investment Capital, Inc. (“PLAINTIFF”), and defendant CLIC Technology, Inc., a Nevada corporation quoted on the OTC Markets under the trading symbol CLCI (“COMPANY”).

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