eased Defendant Party shall be deemed to have, and by operation of the Judgment shall have, expressly waived the provisions, rights, and benefits of California Civil Code § 1542, which provides: A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in

to defraud Protempo into providing an up-front payment of $1,910,794 and to pay other sums, such as to constitute fraud, oppression and malice under California Civil Code section 3294. By virtue of Defendant's willful and wrongful conduct, Protempo is entitled to punitive and exemplary damages. SECOND CAUSE OF

eased Defendant Party shall be deemed to have, and by operation of the Judgment shall have, expressly waived the provisions, rights, and benefits of California Civil Code § 1542, which provides: A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST I