SETTLEMENT AND RELEASE AGREEMENT
This Settlement and Mutual General Release Agreement (hereinafter "Agreement") is made and entered into this
18th day of January, 2001, by and amongst Mull Acres Investments, Inc., Jeffrey H. Silvers, William Alden and
Carl Vincent "Vini" Bergeman ("Cross-Defendants"), on the one hand, and Ultra Motorcycle Company, f/k/a
Bikers Dream, Inc ("Cross-Complainant"), on the other hand. Cross-Complainant and Cross-Defendants are
hereinafter sometimes collectively referred to as "Parties."
1.01. Certain disputes have arisen between the Parties. The purpose of this Agreement is to resolve, in their
entirety, all disputes that now exist, or potentially could exist, between the Parties relating to those claims and
disputes which are, or could have been, set forth in the action pending in the Superior Court of the State of
California in and for the County of Riverside entitled: Mull Acres Investments, Inc v. Bikers Dream, Inc et. al,
(and related cross actions) Case No. RIC 338208. This action may sometimes be referred to hereinafter as the
1.02. It is the desire and intention of the Parties to this Agreement to settle all disputes between them that are, or
could have been, included in the Litigation.
2.01. NOW, THEREFORE, in exchange for mutual releases and for a full and adequate consideration, receipt of
which is hereby acknowledged, and the terms, conditions, and covenants contained herein, the Parties hereto
agree as follows:
2.02. Recitals. The recitals set forth here in above are incorporated herein by this reference and made a part of
this Agreement between the Parties.
2.03. Terms. Cross-Defendants and Cross-Complainant intend to settle and resolve all of the issues in the
litigation with this agreement. No Cross-Defendant shall have to pay Cross-Complainant any monies as a result
of this settlement. Nor, shall Cross-Complainant have to pay any monies to any Cross-Defendant. All Cross-