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<br /> S'lfC
<br /> Jon N. Coffee and their legal representatives, heirs, assigns, agents, employees,
<br /> successors, principles, predecessors, attorneys, shareholders, directors, and insur-
<br /> ance carriers, from and against all security interests of Liberty, and all claims,
<br /> causes of action, losses, costs and expenses, obligations, liabilities, damages and
<br /> demands of any kind whatsoever, whether arising in equity or under common law,
<br /> statute, contract or by any other authority that Liberty may have in the Law-
<br /> suit. Liberty releases and relinquishes all further rights to any and all property
<br /> of CEI, the funds presently on deposit with In terna tional (in the name of CEl).
<br /> and all notes, receivables from CEI and all guarantees from Jon N. Coffee.
<br /> Liberty further agrees that the balance of all CEl's and Jon N. Coffee's loan
<br /> and deposit accounts at Liberty are a zero balance. Bank One, however,
<br /> expressly reserves the right to participate in any distributions to unsecured credi-
<br /> tors in the CEl Bankruptcy case and Jon N. Coffee's individual bankruptcy case.
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<br /> 5. No Assignment. Each Party hereto warrants, represents and
<br /> agrees that it has not assigned, subrogated, or transferred, or purported to
<br /> assign, subrogate or transfer to any person, firm, partnership, corporation or
<br /> entity, whatsoever any claims, actions, demands, or causes of action, charges,
<br /> obligations, or liabilities herein above released. Each Party warrants, represents,
<br /> and agrees to indemnify, defend and hold such other Party harmless from any
<br /> such assignment, subrogation or transfer of claims, actions, demands, or causes of
<br /> action.
<br /> 6. No Admission. It is expressly agreed and understood that the
<br /> agreements herein contained and consideration transferred are to compromise
<br /> disputed claims, avoid litigation and buy peace, and that no payment made or
<br /> other consideration given shall be construed as an admission of liability, all lia-
<br /> bility being expressly and vigorously denied.
<br /> COMPROMISE AND SETTLEMENT AGREEMENT AND MUTUAL RELEASE PaRe 8
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