SETTLEMENT AGREEMENT AND MUTUAL RELEASE
This Settlement Agreement and Mutual Release ("Agreement") is made and entered into as of January 19, 2001
by and between WILLIAM S. PERELL, and CHERYL HARRISON doing business as HARRISON DESIGN
GROUP (collectively referred to as "Claimants"), on the one hand, and EXSTREAM DATA, INC. (formerly
known as E-Fax Communications, Inc.) a California corporation ("Exstream"), JOSEPH KARWAT, ERIC
KARLSON, and ROBERT DUMPER (collectively referred to as "Defendants"), on the other hand.
E*COMNETRIX, INC., a Canadian corporation ("E*Comnetrix"), is also a party to this Agreement.
WHEREAS, on June 5, 2000, plaintiff William S. Perell filed a complaint against Defendants, and others, in the
Alameda County Superior Court for the State of California (Case No. 826985-0), and then on July 12, 2000,
filed a First Amended Complaint against the same Defendants, and others, containing causes of action for
declaratory relief, fraud, conspiracy, breach of fiduciary duty and injunctive relief (referred to hereafter as "the
WHEREAS, by execution of this Agreement, the parties hereto wish to terminate the Action, with prejudice, and
wish to settle and dispose of any and all potential or existing claims concerning the subject matter of the Action,
including the following additional potential claims by Claimants:
(a) All potential claims against Sanford H. Margolin, Esq. and the law firm of Margolin & Biatch arising from the
facts set forth in the Complaint;
(b) All potential claims for attorneys' fees under the Settlement Agreement and Release between William S. Perell
and Exstream Data, Inc. dated January 14, 1997; and
(c) All potential claims that Claimants were wrongfully precluded from participating in the September 2000 share
tender offer by E*Comnetrix, Inc.
WHEREAS, Claimants and Defendants wish mutually to release each and every existing and potential known or
unknown dispute, claim, lawsuit, cause of action and/or issue relating to th