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LAW OFFICES OF DONALD F. TOMPKINS
2 Lenox Road, P.O. Box 1812
Wayne, New Jersey 07470-1812
Tel. (973 633-1792, Fax (973) 633-0461
Attorney for the Plaintiff
Superior Court of New Jersey,
Law Division - Passaic County
Docket No PAS-L-1796-99
_______________________________
JOSEPH LA BRUNA,
Plaintiff(s)
Vs.
TREVOR G. MARSHALL,
YARC SYSTEMS CORPORATION,
And DOES 1 THROUGH 20
Defendant(s)
______________________________
It Is hereby stipulated and agreed as of the 5th day of June,
2000, by the Plaintiff and the Defendants that the above entitled
action is settled upon the following terms and conditions:
1. YARC Systems Corporation will deliver Fifty Thousand Dollars
($50,000.00) to the plaintiff's attorney, witihin sixty days from the
date first shown above. If delivery is not made by that date, plaintiff
shall notify defendants attorney and defendant YARC Systems Corporation
shall have a thirty day grace period from the initial default date in
which to deliver said funds. No further grace period or extension shall
be given.
2. If delivery is not timely made of the above mentioned Funds
within the time period stated plaintiff may submit to the Court, with
notice to defendant's attorney, an affidavit certifying the breach of
this Stipulation of Settlement. The Court will thereafter enter
Judgement in favor of the plaintiff and against YARC Systems
Corporation for Fifty Thousand Dollars ($50,000.00) plus a Ten Thousand
Dollar ($10,000.00) penaly for a total of Sixty Thousand Dollars
($60,000.00). In the event that partial payments have been timely made
by YARC, the affidavit will state the amounts received by the
plaintiff. In the event that the full amouunt has not been paid, the
judgement shall be for the amount of Sixty Thousand dollars, less the
amount that has been timely paid.
3. I, Joseph LaBruna, hereby release defendant Trevor G. Marshall
and YARC Systems Corporation from any and all claims and demands of any
nature what so ever, that I have against either of them. This includes
those claims and demands of which I am not aware and those not
specifically mentioned herein. This release applies to claims resulting
from anytrhing, which has happened up to the date first mentioned
above. I specifically release any and all claims against Trevor G.
Marshall and YARC Systems Corporation, which arose out of, or in
connection with my employment by YARC Systems Corporation.
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4. We, Trevor G. Marshall and YARC Systems Corporation, hereby release
Joseph LaBruna from any and all claims and demands of any nature what
so ever that we have against him. This includes those claims of which
we are not aware and those that are not specifically mentioned herein.
This release applies to claims resulting from anything which has
happened up to the date first mentioned above. We specifically release
any and all claims against which arose out of, or in any way connected
with Joseph LaBruna's employment by YARC Systems Corporation.
5. In the event a non-signatory to this stiputaion commences an action
or arbitration against either of the defendants, claiming that it is
entitled to damages as a result of the plaintiff's tortuous conduct,
breach of contract, strict liability or otherwise wrongful, negligent
or reckless conduct while the plaintiff was employed by YARC, the
defendant(s) shall have the right to cross claim against plaintiff for
the amount of damages alleged by the third party. It is specifically
acknowledged that the defendant(s) are not releasing plaintiff from
potential tax liability that the Internal Revenue Service may have
against Plaintiff. Defendants warrant that no such action or
arbitration currently exists against the defendants.
6. The within acion is hereby dismissed in accordance with this
Stipulation of Settlement.
7. We have signed this Stipulation of Settlement and Release after it
was read and explained to us and we understand the terms and conditions
herein. We acknowledge and consent to the entry of this Stipulation of
Settlement. We have been given a fully executed copy of this document.
YARC Systems Corporation
By: /s/ Trevor G. Marshall, CEO /s/ Trevor G. Marshall
/s/ Joseph LaBruna
As to form: As to form:
/s/Christopher Strahan, Esq. /s/ Donald F. Tompkins, Esq
Attorney for Defendants Attorney for Plaintiff
