Document for MDL MASTER FILE

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                                CAUSE NO. CL-22-1155-E                                                        December 09, 2022




                            MEMORANDUM OF SETTLEMENT

        Plaintiff(s) Delia Ruiz agree(s) to settle any and all claims and/or causes of action(s)
against the Defendant(s) Foremost Lloyds of Texas in consideration for the payment of
$ 20,000.00_by Defendant(s). This settlement is a release of any and all causes of action and/or
claim(s) that Plaintiff(s) and/or Defendant(s) may have which relate to the claims described in the
Plaintiff's Original Petition/complaint or any amended petitions/complaints. Said complaint(s) are
incorporated into this Memorandum of Settlement by reference.

        Defendant(s) agree(s) to submit settlement funds to the Plaintiff(s) upon receipt of a signed
and notarized release and dismissal. Defendant(s) will draft all appropriate settlement and release
of all claims documents to include dismissal documents. All parties will agree to cooperate in
finalizing these documents and obtaining appropriate signatures at the time of payment. All
taxable court costs including mediators fee will be paid by each party.

         This Memorandum of Settlement is a binding agreement on all parties to this controversy.
This Memorandum of Settlement may be filed with the court as a binding Rule 11 agreement by
any party. A duly filed photo copy will be substituted for the original which will be maintained
by the mediator. This Memorandum of Settlement incorporates the general conditions and terms
of settlement and contemplates a more thorough document to be drafted by the parties.

         The parties represent and warrant that: (i) they have carefully reviewed this Settlement
agreement; (ii) they have consulted with their attorneys concerning this Settlement Agreement;
(iii) any questions that they have pertaining to this Settlement Agreement have been answered and
fully explained by their attorneys; (iv) their decision to execute this Settlement Agreement was not
based on any statement or representation, either written or oral, made by any person or entity other
than those statements contained in this Settlement Agreement, and specifically was not based on
any statement or representation made by any opposing party or its counsel; (v) this Settlement
Agreement constitutes the entire agreement and understanding between the parties; (vi) they have
entered into this Settlement Agreement of their own free will; and (vii) all prior and
contemporaneous agreements, understanding, representations and statements, whether written or
oral, are merged herein.




                                                                                         EXHIBIT A
       Other essential elements of the settlement of this matter are:

1.     60 % to        Plaintiff and Plaintiff Attorney

2.     40 %    to     Plaintiff and Bank of America

All Settlements Include:

full and final release of all parties
each pay own fees, expenses, etc.
Plaintiff agrees to Indemnity for anyone claiming by, through, or under
Plaintiff agrees to Standard Confidentiality Agreement
Plaintiff agrees to all property damage claims released through date of settlement.
Plaintiff agrees to provide drafting instructions and W-9 ASAP
Plaintiff agrees to sign Farmers Standard Release
Plaintiff agrees the settlement amount includes release of all property damage , ALE, and
contents claims

     I UNDERSTAND AND AGREE TO THE TERMS OF THIS MEMORANDUM OF
SETTLEMENT.

Plaintiff's attorney:___________________________

Plaintiff:___________________________________


Defendant Representative:_____________________

                      /s/ Natalie D. Tarnosky
Defendant's attorney:_________________________

Defendant:_________________________________

Mediator:__________________________________

Tax I.D. No.: _______________________________