![](data:image/png;base64,iVBORw0KGgoAAAANSUhEUgAAAHkAAAABCAIAAAB16ZayAAAACXBIWXMAABYlAAAWJQFJUiTwAAAADUlEQVQY02NgGAX0AgABbAABk3ccYwAAAABJRU5ErkJggg==)
EXECUTION VERSION
regarding the
enforcement of this Agreement, each Party and its respective heirs, family
members, executors, divisions, affiliates, subsidiaries, parents, branches, predecessors,
successors, assigns, and, with respect to such persons, their past, present and future
officers, directors, managers, trustees, employees, servants, agents, shareholders,
members, investors, administrators, general or limited partners, representatives, insurers,
fiduciaries, advisors, attorneys, affiliates, and other agents fully, completely,
unconditionally and forever, RELEASES and DISCHARGES each other Party and its
respective heirs, family members, executors, divisions, affiliates, subsidiaries, parents,
branches, predecessors, successors, assigns, and, with respect to such persons and
individuals (inclusive of any and all capacities, including, without limitation, professional,
fiduciary, representational, individual and personal) their past, present and future officers,
directors, managers, trustees, employees, servants, agents, shareholders, members,
investors, administrators, general or limited partners, representatives, insurers, fiduciaries,
advisors, attorneys, affiliates, and other agents, from any and all agreements,
compensation, complaints, controversies, costs, damages, debts, demands, expenses,
grievances, losses of service, promises, claims, causes of action, rights, remedies, duties,
obligations, actions, omissions, loss, or liability whatsoever, whether known or unknown,
directly or indirectly arising from or out of, growing out of, based upon, in whole or in
part, or attributable to, events, acts or omissions occurring in whole or part from the
beginning of time through to the date of the Final Settlement Order, regardless of whether
any such claims or causes of action have yet accrued.
B. Further, notwithstanding that no Party intends to release
its own attorneys as a result of
the releases set forth in this Section 15, because and to the extent that Baron, Ondova, the
Trusts, Domain Jamboree Parties and/or any of their affiliated entities (collectively, the
“Baron Parties
”) claim, or have claimed in the past, that certain opposing attorneys have
also allegedly acted as his, her, its or their legal counsel, agent or representative in any
other capacity, which allegations are understood by all of the undersigned as disputed fact
issues to be compromised by this Agreement, the Baron Parties and all other Parties state,
represent and agree that each of the following have never been attorneys, agents or
representatives of, or represented in any professional capacity, the Baron Parties for any
purpose and are receiving complete releases in any and all capacities, including, without
limitation, professional, fiduciary, representational, individual and personal: John
MacPete, Paul Storm, any attorneys at Storm LLP, Dean Hinderliter, any attorneys at
Locke, Liddell & Sapp, LLP, any attorneys at Locke Lord Bissell & Liddell, LLP, A.J.
Stone, any attorneys at Bolt & Nagi, Frank Perry, any attorneys at Payne & Blanchard,
Denis Kleinfeld, any attorneys at The Kleinfeld Firm, any attorneys at Rothstein,
Rosenfeld & Adler, Melissa Hayward, any attorneys at Flynn, Skierski, Lovell &
Hayward, Ravi Puri, Sharon Hotchkiss, Daniel J. Sherman, any attorneys at Sherman &
Yaquinto, Raymond J. Urbanik and any attorneys at Munsch Hardt Kopf & Harr, P.C.
Further, and to the same effect, the Manila Parties state, represent and agree that each of
the following have never been attorneys, agents or representatives or represented in any
professional capacity the Manila Parties for any purpose and are receiving complete
releases in any and all capacities, including, without limitation, professional, fiduciary
representational, individual and personal: West & Associates, LLP, Craig Capua,
Hohmann, Taube & Summers, LLP, Eric Taube, Raymond J. Urbanik, M’Lou Patton
Bell, Munsch Hardt Kopf & Harr P.C., Jeff Hall, Gerrit Pronske, Pronske Patel, LLC,
John M. Cone and Hitchcock Everet, LLP. Additionally, and to the same effect, Baron,
Ondova and the Domain Jamboree Parties state, represent and agree that each of the
following have never been attorneys, agents or representatives or represented in any
professional capacity Baron, Ondova and/or the Domain Jamboree Parties for any purpose
19
MHDocs 2609061_21 11236.1
Case 09-34784-sgj11 Doc 368-1 Filed 07/02/10 Entered 07/02/10 15:40:01 Page 19 of
115