LifeLock 2015 Annual Report Download - page 308

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 150 of 289
constitutional, contractual, and common law claims for damages, costs, expenses, extra contractual damages, compensatory
damages,exemplary damages, special damages, consumer redress, penalties, punitive damages, and/or damage multipliers,
disgorgement, declaratory relief, equitable relief, injunctive relief, expenses, interest, and/or attorneys' fees and costs against LifeLock.
2. Litton has read Section 1542 of the Civil Code of the State of California, which provides as
follows:
A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO
EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER
MUST HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR.
Litton hereby voluntarily waives the rights described in Section 1542 and elects to assume all risks for claims that now exist in his
favor, whether known or unknown, against the Released Parties. Accordingly, this General Release includes within its effect claims
and causes of action which Litton does not know or suspect to exist in his favor at the time of his execution hereof and of the facts and
circumstances relating in any manner to the Released Claims are hereafter found to be other than or different from the facts now
believed to be true, this General Release shall remain effective.
3. Litton warrants and represents that he is the sole and lawful owner of all rights, title, and interest in and to all of the claims
described above and that he has not heretofore voluntarily, by operation of law or otherwise, sold, assigned, or transferred or
purported to sell, assign, or transfer to any other person or entity such claims or any part or portion thereof.
4. To the extent required by law, Garden City Group, LLC as the Settlement Administrator of the Settlement shall issue Litton a
Form 1099 reflecting the payment of any settlement benefits described in the Class Action Settlement Agreement
5. Litton agrees that he alone is responsible for any tax consequences, including any penalties or interest, relating to the payment
of any settlement benefits described in the Class Action Settlement Agreement
6. Litton and the Released Parties expressly agree that any and all force and effectiveness of this General Release is entirely
contingent upon final approval of the Settlement, executed in the Action. Ifthe Settlement does not become final for any reason, then
this General Release shall be null and void ab initio. Neither a modification of nor a reversal on appeal of the Service Award shall
constitute grounds for cancellation or termination of this General Release, however.
Dated: Oct 28, 2015
Brian Litton
/s/ Brian Litton
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