Settlement

SETTLEMENT AGREEMENT

We, Steve Sissons and Lisa Sissons, hereby agree to accept the sum of TWO HUNDRED AND NINETY THOUSAND AND NO CENTS ($290,000.00) USD in full satisfaction and final settlement of any and all claims which we have or may have against the United States, its officers, agents and employees, jure proprio and jure successionis, for personal injury and wrongful death arising from the death of Finley Sissons in Naples, Italy, on March 26, 2012, and for any and all damages, injuries, and losses proximate and consequent thereto.

In consideration hereof, we hereby release and forever discharge the United States, its officers, agents, and employees, from all liability, claims and demands of whatsoever nature arising from said incident.

It is understood that the amount tendered is accepted in full satisfaction and final settlement and that the award is made pursuant to the Foreign Claims Act, 10 U.S.C. § 2734, which provides for the administrative settlement of disputed claims against the United States arising from its activities, and is not to be construed as an admission of liability on the part of, but as a release of, the United States, its offers, agents, and Payment of the settlement amount will be made by government wire transfer as per the following:

Claimants’ attorney agrees to distribute the settlement proceeds among the claimants.