MUTUAL RELEASE
KNOW ALL MEN BY THESE PRESENTS that Cheetah Oil
& Gas Ltd. (“Cheetah Nevada”), a Nevada company,
Cheetah Oil & Gas Ltd., a British Columbia company and Scotia
Petroleum Inc. (“Scotia”), a British Columbia company
(collectively, the “Cheetah Parties”) and Paradigm
United Kingdom Ltd., David Powell, Troy McIntyre and Wayne
Richards, (collectively, the “Scotia Shareholders”) for
the issuance of certain restricted shares of common stock in
Cheetah Nevada (the “Settlement Shares”) to the Scotia
Shareholders as indicated on Schedule “A” attached
hereto, in consideration for the outstanding shares of Scotia held
by the Scotia Shareholders, and for other good and valuable
consideration, the receipt and sufficiency of which are
acknowledged by each party, agree as follows:
1. Each party hereby remises, releases and
forever discharges each other and their respective assigns,
directors, officers, shareholders, employees and servants, and,
where applicable, the heirs, executors, administrators, successors
and assigns of each other from any and all manner of action and
actions, cause and causes of action, suits, debts, dues, sums of
money, claims, demands and obligations whatsoever, at law or in
equity, which each party may have had or now have or which their
assigns, receivers, receiver-managers, trustees, affiliates, and,
where applicable, the heirs, executors, administrators, successors
and assigns of each other hereafter can, shall or may have existing
up to the present time by reason of any matter cause or thing
whatsoever relating to or arising out of the relationship between
the parties relating to, arising out of or in connection with any
and all dealings between the parties up to and including the date
of this Mutual Release.
2. Notwithstanding the above provision and for
greater clarification, this Mutual Release does not bar any claims
that may arise from facts that occur after the date of this Mutual
Release.
3. It is understood and agreed that neither
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