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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION In re: CHARLES HOMER DUNLAP, LUCILLE GRACE DUNLAP Debtors, _________________________________________ STRUCTURED INVESTMENTS CO., LLC, Plaintiff, v. CHARLES HOMER DUNLAP and LUCILLE GRACE DUNLAP, Defendants. STIPULATION AND AGREED ORDER ON AMENDED MOTION FOR AWARD OF ATTORNEYS FEES This matter comes before the Court on the Defendants Amended Motion for Award of Attorneys Fees (Motion- Docket Entry No. 101) and by agreement, herein (Stipulation), the parties stipulate as follows: 1. On November 10, 2011, the Defendants filed an amended motion for award of attorneys fees and memorandum in support thereof seeking an award of attorneys fees and costs in the amount of $40,277.68 associated with the defense of this adversary proceeding. 2. On November 23, 2011, the Plaintiff filed its Response in Opposition to Defendants Amended Motion for Award of Attorneys Fees. APN: 10-07041-SCS Case No. 09-75282-SCS Chapter 7

Nicole A. Rosenblum, VSB No. 42780 Crowley, Liberatore, Ryan & Brogan, P.C. 150 Boush St., Suite 300 Norfolk, VA 23510 Telephone: (757) 333-4500 Facsimile: (757) 333-4501 Counsel for the Defendants/Debtors

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3. On November 30, 2011, the Defendants filed their Reply to Plaintiff's Response in Opposition to Defendants' Amended Motion for Award of Attorney's Fees. 4. After considering the costs, facts, circumstances, and the risk associated with the Motion, it is now the desire and intention of the Plaintiff and the Defendants to resolve Defendants Motion against the Plaintiff. 5. The Defendants have agreed to accept, and Plaintiff has agreed to pay, $25,000.00 in full and complete satisfaction of the Defendants Motion (Settlement) upon the following terms: a. The Plaintiff shall pay $15,000.00 (First Payment) to Defendants within 10 business days of entry of this order approving this Stipulation, or February 1, 2012 whichever is later; and, b. The Plaintiff shall pay an additional $10,000.00 to Defendants on or before fortyfive (45) days after the payment of the First Payment by the Plaintiffs. 6. Payments shall be made in immediately available funds (i.e., personal check, cashiers check, or money order at Plaintiffs option) payable to and delivered to counsel for the Defendants, Crowley, Liberatore, Ryan & Brogan, P.C., 150 Boush Street, Suite 300, Norfolk, VA 23510. 7. If any payment or any portion of any payment required to be made under the terms of the Settlement is not received by the date that it is due, or is denied for insufficient funds, (Default Amount), then the Plaintiff shall be in default under this Stipulation. In such event, Defendants counsel shall provide via first-class, US Mail postage prepaid, with or without delivery confirmation as elected by Defendants, stating the Default Amount to the Plaintiff and counsel as follows: Structured Investment Co., LLC at 7777 Center Ave., Suite 390 Huntington Beach, CA 92647 and Counsel for Plaintiff at 16030 Ventura Blvd., Ste. 470 Encino, California 91436 (the Notice of Default). If the Plaintiff does not cure the default by paying the Default Amount or it fails to file an objection to the alleged Default Amount, and notice thereof, within 10 days of receipt of the Notice of Default, Defendants, by counsel, shall tender an order to the

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Court entering judgment (Judgment Order) against the Plaintiff in the amount of $40,277.68, reduced by any sums already paid by Plaintiff, with interest at the applicable federal judgment rate, from the date of entry of the Judgment Order plus reasonable attorneys fees and costs associated with the collection of the judgment. See Exhibit A. 8. If Plaintiff makes the payments as agreed by the due date, the Defendants, by counsel, shall within a reasonable time but no more than 15 business days after receipt of full payment of Settlement, tender an order to the Court that the claim is satisfied and seek the dismissal of this matter with prejudice (see Exhibit B). FOR THESE REASONS AND FOR GOOD CAUSE SHOWN, IT IS ORDERED that: A. The Plaintiff shall pay $25,000.00 in settlement as follows: a. The Plaintiff shall pay the First Payment to Defendants within 10 days of entry of this order approving this Stipulation, or February 1, 2012, whichever is later; and b. The Plaintiff shall pay an additional $10,000.00 to Defendants on or before fortyfive (45) days after payment of the First Payment. c. The Plaintiff shall make all payments in immediately available funds made payable to and delivered to Crowley, Liberatore, Ryan & Brogan, P.C., 150 Boush Street, Suite 300, Norfolk, VA 23510. C. If any payment or portion of any payment required to be made hereunder this Stipulation and Settlement is not received by the date that it is due, or denied for insufficient funds, then the Defendant shall immediately issue a Notice of Default to Plaintiff and Plaintiffs counsel, at the addresses provided above. If the Plaintiff does not (1) cure the default with 10 days of the receipt of the Notice of Default or (2) file an objection to the alleged Default Amount or Notice of Default and notice thereof, Plaintiff shall be in default under this Stipulation. Defendants counsel shall tender an Order to the Court entering judgment (Judgment Order) against the Plaintiff in the amount of $40, 277.68, reduced by any sums already paid by Plaintiff, with interest at the applicable federal judgment rate, from

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the date of entry of the Judgment Order plus reasonable attorneys fees and costs associated with the collection of the judgment. D. If Plaintiff makes all payments in accordance with the terms of this Settlement, the Defendants, by counsel, shall tender an order to the Court that the claim is satisfied within a reasonable time but no more than 15 business days after receipt of full payment of the Settlement and seek the dismissal of this matter with prejudice (see Exhibit B).

ENTERED:

/s/ Stephen C. St.John Jan 27 2012

United States Bankruptcy Judge WE ASK FOR THIS: /s/Nicole A. Rosenblum Nicole A. Rosenblum, VSB No. 42780 Crowley, Liberatore, Ryan & Brogan, P.C. 150 Boush St., Suite 300 Norfolk, VA 23510 Telephone: (757) 333-4500 Facsimile: (757) 333-4501 Counsel for the Defendants/Debtors /s/Thomas B. Dickenson Thomas B. Dickenson DICKENSON & DICKENSON 1170 Lexan Ave, Ste 203 Norfolk, VA 23508-1274 Craig G. Margulies, Esq The Margulies Law Firm, APLC 16030 Ventura Blvd, Ste 470 Encino, CA 91436 Attorneys Structured Investments Co., LLC.
Entered on Docket: 1/30/12

(permission to affix signature given via electronic mail on 1-25-12)

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CERTIFICATE OF ENDORSEMENT I certify that in accordance with Local Rule 9022-1(C)(1), this Order has been endorsed by all necessary parties. /s/Nicole A. Rosenblum

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EXHIBIT A
UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION In re: CHARLES HOMER DUNLAP, LUCILLE GRACE DUNLAP Debtors, _________________________________________ STRUCTURED INVESTMENTS CO., LLC, Plaintiff, v. CHARLES HOMER DUNLAP and LUCILLE GRACE DUNLAP, Defendants. JUDGMENT ORDER This matter having come before the Court upon the Defendants Amended Motion for Award of Attorneys Fees against the Plaintiff and pursuant to the Stipulation and Agreed Order and the Court being sufficiently advised finds as follows: 1. This is a core proceeding over which this Court has jurisdiction pursuant to 28 U.S.C. Section 157(3) and 28 U.S.C. Section 1334. Venue is proper in this district pursuant to 28 U.S.C. Section 1409. 2. The Parties had entered into a settlement agreement whereby the Plaintiff was to make payments to the Defendants in the amount of $25,000.00 in full and complete satisfaction of the Defendants Motion (Settlement) as follows: a. The Plaintiff shall pay $15,000.00 (First Payment) to Defendants within 10 business days of entry of the Stipulation and Agreed Order or February 1, 2012 whichever was later; and,
Nicole A. Rosenblum, VSB No. 42780 Crowley, Liberatore, Ryan & Brogan, P.C. 150 Boush St., Suite 300 Norfolk, VA 23510 Telephone: (757) 333-4500 Facsimile: (757) 333-4501

Case No. 09-75282-SCS Chapter 7

APN: 10-07041-SCS

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Counsel for the Defendants/Debtors

b. The Plaintiff shall pay an additional $10,000.00 to Defendants on or before forty-five (45) days after the payment of the First Payment by the Plaintiffs. 3. The Court further finds the Plaintiff has failed to make the payments in accordance with the terms of the Settlement, including the Notice of Default as provided in the Agreement, and therefore the Plaintiff is in default of the Settlement. IT IS THEREFORE ORDERED, ADJUDGED, AND DECREED that judgment is granted and hereby entered against Structured Investments Co., LLC in favor of the Defendants in the amount of $40,277.68, reduced by any sums already paid by Plaintiff (amount to be inserted) , with interest at the applicable federal judgment rate, from the date of entry of this Order plus reasonable attorneys fees and costs associated with the collection of the judgment.. Defendants shall further be entitled to reasonable attorneys fees and costs associated with collection. This is a final appealable order, and there is no just reason for delay. IT IS SO ORDERED.

ENTERED: STEPHEN C. ST. JOHN United States Bankruptcy Judge

I ASK FOR THIS:

Nicole A. Rosenblum, VSB No. 42780 Crowley, Liberatore, Ryan & Brogan, P.C. 150 Boush St., Suite 300 Norfolk, VA 23510 Telephone: (757) 333-4500 Facsimile: (757) 333-4501 Counsel for the Defendants/Debtors

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CERTIFICATION I hereby certify that on (date to be inserted) in accordance with Local Bankruptcy Rule 9022-1(C)(2) a copy of this order has been served upon counsel for the plaintiff as follows: Thomas B. Dickenson DICKENSON & DICKENSON 1170 Lexan Ave, Ste 203 Norfolk, VA 23508-1274 Craig G. Margulies, Esq Fahim Farivar, Esq The Margulies Law Firm, APLC 16030 Ventura Blvd, Ste 470 Encino, CA 91436

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EXHIBIT B
UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION In re: CHARLES HOMER DUNLAP, LUCILLE GRACE DUNLAP Debtors, _________________________________________ STRUCTURED INVESTMENTS CO., LLC, Plaintiff, v. CHARLES HOMER DUNLAP and LUCILLE GRACE DUNLAP, Defendants. DISMISSAL ORDER This matter having come before the Court upon the Defendants Amended Motion for Award of Attorneys Fees, the Plaintiff having filed an answer to said motion; and the Court being sufficiently advised finds as follows: 1. This is a core proceeding over which this Court has jurisdiction pursuant to 28 U.S.C. Section 157(3) and 28 U.S.C. Section 1334. Venue is proper in this district pursuant to 28 U.S.C. Section 1409. 2. The Parties had entered into a settlement agreement whereby the Plaintiff was to make payments to the Defendants in the amount of $25,000.00 in full and complete satisfaction of the Defendants Motion (Settlement) as follows: a. The Plaintiff shall pay $15,000.00 (First Payment) to Defendants within 10 business days of entry of the Stipulation and Agreed Order, or February 1, 2012 whichever is later,; and,
Nicole A. Rosenblum, VSB No. 42780 Crowley, Liberatore, Ryan & Brogan, P.C. 150 Boush St., Suite 300 Norfolk, VA 23510 Telephone: (757) 333-4500 Facsimile: (757) 333-4501

Case No. 09-75282-SCS Chapter 7

APN: 10-07041-SCS

Case 10-07041-SCS

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Counsel for the Defendants/Debtors

b. The Plaintiff shall pay an additional $10,000.00 to Defendants on or before forty-five (45) days after the payment of the First Payment by the Plaintiff. 3. The Court further finds the Plaintiff has made the payments in full in accordance with the terms of the Settlement Agreement. IT IS THEREFORE ORDERED, ADJUDGED, AND DECREED that this matter is SETTLED and dismissed with prejudice from the Courts docket.

ENTERED: STEPHEN C. ST. JOHN United States Bankruptcy Judge

I ASK FOR THIS:

Nicole A. Rosenblum, VSB No. 42780 Crowley, Liberatore, Ryan & Brogan, P.C. 150 Boush St., Suite 300 Norfolk, VA 23510 Telephone: (757) 333-4500 Facsimile: (757) 333-4501 Counsel for the Defendants/Debtors CERTIFICATION I hereby certify that on (date to be inserted) in accordance with Local Bankruptcy Rule 9022-1(C)(2) a copy of this order has been served upon counsel for the plaintiff as follows: Thomas B. Dickenson DICKENSON & DICKENSON 1170 Lexan Ave, Ste 203 Norfolk, VA 23508-1274 Craig G. Margulies, Esq Fahim Farivar, Esq The Margulies Law Firm, APLC 16030 Ventura Blvd, Ste 470 Encino, CA 91436