SETTLEMENT AGREEMENT AND MUTUAL RELEASE
This Settlement Agreement and Mutual Release (“Agreement”) is entered into by and between
SECURED DIVERSIFIED INVESTMENT, a Nevada Corporation authorized to do business in California
(“SDI”), on one hand, and LUIS LEON, an individual (“Mr. Leon”), and MARIA LEON, an individual (“Mrs.
Leon”), (Collectively, “Plaintiffs” or the “Leons”) on the other hand, (sometimes collectively referred to herein as
the “Parties”) with reference to the following recitals:
On or about July 2004, SDI and Mr. Leon into an employment relationship in which Mr.
Leon was hired as Chief Executive Officer of SDI.
On or about January 5, 2005, SDI terminated Mr. Leon’s employment.
The Leons subsequently filed a lawsuit on April 1, 2005, styled Luis Leon, an individual, et.
al, v. Secured Diversified Investment, Ltd., a Nevada corporation, with the Superior Court of California in and
for the County of Orange, Central District Case No. 05CC04651, alleging causes of action for Breach of
Contract, Promissory Estoppel, Intentional Misrepresentation, and Labor Code Violations as to Mr. Leon only,
and Intentional Infliction of Emotional Distress and Negligent Infliction of Emotional Distress as to Mr. Leon and
SDI and the Leons would like to avoid the uncertainty, costs and risks involved if this action
is further litigated and, as a result, want to settle the action in its entirety according to the terms of this Agreement.
NOW, THEREFORE, in consideration of the foregoing recitals, promises, mutual covenants and
warranties set forth herein, and for other good and valuable consideration, the receipt of which are hereby
acknowledged, SDI and the Leons agree as follows:
Payment of Settlement Amount
.1. SDI shall pay to the Leons the sum of exactly sixty five thousand dollars ($65,000.00). In