SETTLEMENT AGREEMENT AND FULL AND FINAL RELEASE
This Settlement Agreement and Full and Final Release (“Settlement Agreement”) is entered into effective September 10,
2007, by and between Michael H. Schoeffler, an individual (“Schoeffler”) and Quantum Fuel Systems Technologies Worldwide,
Inc., a Delaware corporation, (“Quantum”) with respect to the following facts:
A. On March 5, 2007, Quantum commenced arbitration (the “Arbitration”) against Schoeffler with the American Arbitration
Association (“AAA”), seeking an award that Quantum is not liable to Schoeffler. Schoeffler has counterclaimed against
Quantum in the Arbitration.
B. Quantum and Schoeffler (collectively referred to as the “Parties”), without admitting any liability or fault, now wish to
settle and compromise their dispute in accordance with the terms set forth below.
NOW, THEREFORE, in consideration of the following mutually agreed covenants and other valuable consideration, the
receipt and sufficiency of which is acknowledged, the Parties agree as follows:
1. Definitions . For purposes of this Settlement Agreement, the following definitions shall apply:
A. “Quantum” means and includes its predecessors, successors, assigns, parents, subsidiaries, affiliates, officers,
directors, employees, shareholders, attorneys, agents, representatives and heirs, and any person or entity who may claim
by or through any of them.
B. “Schoeffler” means and includes his predecessors, successors, assigns, affiliates, employees, employers,
attorneys, agents, representatives and heirs, any entity in which Schoeffler has an ownership interest, and any person or
entity who may claim by or through any of them.
2. Settlement Amount . Quantum shall pay Schoeffler the total sum of Six Hundred Thousand ($600,000) dollars (the
“Settlement Amount”). Upon execution of this Agreement, the parties shall enter a Consent Arbitration Award, in the form
attached to this Agreement as Exhibit A. The Settlement Amount shall be paid to Schoeffler and