SETTLEMENT AGREEMENT AND GENERAL RELEASE
This Settlement Agreement and General Release ("Agreement") is made and entered into on this the
______ day of October, 2007, by, between and among the following parties: Wayne Wade a/k/a N. Wayne
Wade (“Wade”), Bio Solutions Manufacturing, Inc. (“BSLM”), Bio Solutions Production, Inc. (“BSP”), Louis H.
Elwell III (“Elwell”), Bio Solutions Franchise Corp. (“BSFC”), Innovative Industries, LLC (“Innovative”) ,
BioSolutions of Louisiana, LLC (“BSL”), Environmental Services of Mississippi, LLC (“ESM”), Wade’s Farm,
LLC (“WFL”), Sabrina Baio (“Baio”), Amanda Best (“Best”), David S. Bennett (“Bennett”), Patricia M.
Spreitzer (“Spreitzer”), and Tarun Mendiratta (“Mendiratta”), hereinafter collectively referred to as the "Parties".
BSLM, BSP, Bennett, and Spreitzer are collectively defined as the “BSLM Parties”. Wade, Elwell, BSFC,
Innovative, BSL, ESM, WFL, Baio and Best are collectively defined as the “BSFC Parties”. The Parties hereby
agree as follows:
WHEREAS, on June 8, 2007, Wade initiated an action against BSLM in the United States District Court
for the Southern District of Mississippi, Hattiesburg Division (the “Court”), Civil Action No. 2:07cv000118-KS-
MTP in which the Parties subsequently raised numerous, counterclaims, cross claims and third party claims
against each other (the "Action"); and
WHEREAS, on July 30, 2007, BSLM filed its Answer and Counterclaim against Wade, and together
with BSP, asserted claims against the BSFC Parties in this Action; and
WHEREAS, on September 14, 2007, the BSFC Parties filed an Answer to Counterclaim, Reply to
Defendants’ Affirmative Defenses, Counterdefendants’ Affirmative Defenses, Counterclaim and Third Party
Complaint against the BSLM Parties and Mendiratta; and
WHEREAS, the Parties wish to settle and compromise this controversy due to the cost and uncertainty
of protracted litigation.
THEREFORE, and in consideration of the covenants and promises set forth herein, the Parties