Tri-S Security Corp – State Court of Fulton County State of Georgia (April 14th, 2009)
This Joint Stipulation of Settlement and Release is made and entered into on the undersigned date, by and between the following parties: Plaintiff Hal Unschuld, individually and on behalf of the class he seeks to represent (Plaintiff or Class Representative), and Defendants Tri-S Security Corporation f/k/a Diversified Security Corporation (Tri-S), Ronald Farrell (Farrell), E. Wayne Stallings (Stallings), Capital Growth Financial, LLC (Capital Growth), and Bathgate Capital Partners, LLC (Bathgate) (each a Defendant and collectively, Defendants). Plaintiff and each of the Defendants are collectively referred to as the Parties, or individually, a Party. All capitalized terms not immediately defined herein are defined in Section I.C. below.