SEP-29-2010 11:06A FROM:

TO: 16132322680 P.3

FULL AND FINAL RELEASE

1. IN TmS RELEASE, the following terms have the following meanings:

(a) "Releasor" means David Franklin Noble on his own behalf and on behalf of his
heirs. executors. administrators. estate trustees. successors and assigns.

(b) "Releasees" means Joel Richler and his heirs, executors, administrators, estate
trustees, successors and assigns, and Canadian Jewish Congress (Ontario Region)
("CJC ONT") and its past, present and future officers, directors, employees,
agents. subsidiaries, affiliates, divisions, successors and assigns. It is understood
and agreed by the parties that "Releasees" does not include any of the other
named defendants identified in the actions commenced in the Ontario Superior
Court of Justice by the Releasor against Mr. Richler and CJC ONT (among
others) bearing court file numbers 07"CV·329851CM3 and 07-CV-338923PDl
(the "Actions").

2. FOR GOOD AND VALUABLE CONSIDERATION consisting of the agreement of

the Releasees to consent to the dismissal against them of the Actions referred to below,
the receipt and sufficiency of which are hereby acknowledged, the Releasor does hereby
remise, release and forever discharge the Releasees and each of them of and from all
manner of actions. causes of action, c1aims or demands which the Releasor ever had, now
has, or may hereafter have in any way related to or arising from or in connection with any
ofthe fol1owing:

(a) Any statements made by either of the Releasees relating to the Releasor made in a
press release dated November 19, 2004 sent to certain members of the Ontario
press on behalf of CJC ONT and VJA Federation of Greater Toronto;

(b) Any republication by third parties at any time of any statements referred to in
paragraph (a) above; and

(c) All of the claims made or which could have been made, and all of the matters
raised or referred to in the Actions.

3. THE RELEASOR agrees that he will not take or continue any proceedings against any
other person, organization, or corporation who might claim in any manner or forum
contribution, indemnity or relief over from the Releasees or either of them in respect of
any matter which is the subject of this Release. It is agreed and understood that if the
Releasor takes or continues such proceedings and the Releasees or any ofthem are added
to such proceedings in any manner whatsoever whether justified .in law or not, the
Releasor will immediately discontinue the proceedings and will be liable to the Releasees
for all legal costs incurred in any such proceeding. This Release shall operate
conclusively as an estoppel in the event that any such proceeding is taken or continued
and may be pleaded as a complete defence and may be relied upon to dismiss the
SEP-29-2010 11:06A FRUM: TO: 16132322680 P.2

proceeding on a summary basis and no objection will be raised by the Releasor that the
other parties to the proceeding were not privy to the formation of this Release. No
defendant to the Actions has claimed in any manner contribution, indemnity or relief over
from the Releasees or either of them in respect of any matter that is the subject of this
Release, nor do any of the defendants to the Actions have the right to do so.
Accordingly, it is understood and agreed that this paragraph is not applicable to the
Actions.

4. IT IS FURTHER UNDERSTOOD AND AGREED that this settlement shall not be

deemed to be any admission of liability whatsoever on the part of the Releasees, which
liability is denied.

5. THE RELEASOR HEREBY CONSENTS AND AUTHORIZES and instructs his

solicitors, Hameed Farrokzhad, to execute on his behalf all necessary documents to
obtain an Order in each of the Actions dismissing the respective Action against the
Releasees with prejudice and without costs.

6. THE RELEASOR warrants and represents that he has read and fully understands the
terms of this Release. has had the opportunity to and has obtained independent legal
advice in respect thereof, and is signing this Release

7. IN WITNESS WHEREOF the Releasor has hereunto set his hand and seal this <2...9
day of5ept. 2010.

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