Filing # 51206145 E-Filed 01/16/2017 01:20:58 PM

MUTUAL GENERAL RELEASE

THIS RELEASE is executed this 30th day of March, 2015, in conformance with the terms
of the settlement, by LAW OFFICES OF JAMES J. GANGITANO, P.A ("Plaintiff'), and
KISEAN ANDERSON, ("Defendant"). Defendant hereby acknowledges his failure to comply
with the payment schedule of the Mutual General Release dated September 17, 2015 and, thus, is
subject to a consent judgment in the amount of $28,500. Plaintiff and Defendant hereby agree to
settlement of the aforementioned amount due and IN CONSIDERATION of TWENTY
THOUSAND DOLLARS ($20,000.00), to be paid in installments by Defendant to Plaintiff, as
follows:
1. $2,000.00 on or before April 1, 2016;
2. $2,000.00 on or before May 1, 2016;
3. $2,000.00 on or before June 1, 2016;
4. $2,000.00 on or before July 1, 2016;
5. $2,000.00 on or before August 1, 2016;
6. $2,000.00 on or before September 1, 2016;
7. $2,000.00 on or before October 1, 2016;
8. $2,000.00 on or before November 1, 2016;
9. $2,000.00 on or before December 1, 2016; and
10. $2,000.00 on or before January 1, 2017.

Plaintiff and Defendant, all on behalf of themselves, their privies, successors and assigns,
remise, release, acquit, satisfy and forever discharge one another from and against any and all
manner of actions, causes of action, suits, debts, accounts, reckonings, damages and claims and
demands whatsoever, which either had against the other by reason of any matter, cause or thing
from the beginning of the world to the date of these presents, and particularly in connection with
the breach of contract claim in the Circuit Court, Orange County, Case Number 2015-CA-0045600, Law Offices ofJames J. Gangitano, P.A. v. Kisean Anderson.
The Defendant hereby stipulates, consents and agrees that in the event Defendant fails to
make timely installment payments as set forth above and after 5 days of such non-compliance
without remedy by the Defendant, the Plaintiff shall be entitled to a consent judgment in the
amount of $28,500.00. This amount reflects the principal amount due, plus interest and attorney's
fees and costs. The Defendant shall be entitled to a setoff against the $28,500.00 stipulated amount
for the total of any amounts paid pursuant to the instant Release.
The Plaintiff and Defendant acknowledges they have read this Release and there are no
other understandings or agreements other than as set out above.
IN WITNESS WHEREOF, Plaintiff and Defendant have caused this Release to be
executed the day and year first above written.
PLAINTIFF

MUTUAL GENERAL RELEASE

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LAW OFFICES OF
JAMES J. GANGITANO, P.A
STATE OF - - - - - - COUNTY OF v~ '-""'.) ~
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The foregoing instrument was acknowledged before me this _ day of Se~er,

~ by JAMES J. GANGITANO, who is personally known to me or has produced
as identification.
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Notary Public, State of __0_--z..i_~_,,.e_.____

DHARMESH AMIN
Commission # FF 920260
Expires October 8, 2019

D~l"-Lt~ ~,.J
Printed Name:
My commission expires: 16( os/<7~ I<\.

Bondod Thru TIO'i Fain Insurance 800-385-7019

DEFENDANT
KISEAN ANDERSON
STATE OF - - - - - - - COUNTYOF - - - - - The foregoing instrument was acknowledged before me this _ _ day of September,
2015, by KISEAN ANDERSON, who is personally known to me or has produced
as identification.
Notary Public, State of _ _ _ _ _ _ _ __

Printed Name:
My commission expires:

MUTUAL GENERAL RELEASE

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