SETTLEMENT RELEASE -
"MEAN, LLC" -
Do NOT try to type into the white 'Release'- Only type your name, date of birth at bottom of the Release- on the green form section where you will sign.

EXHIBIT A GENERAL RELEASE

This General Release (hereinafter referred to as the “Release”) is made and entered into by and between Plaintiff __________________________, Date of Birth.: _________ in the civil action: Harris Stanfield v. MEAN LLC, et al., bearing Index No. 810317/2023 (hereinafter referred to as “Plaintiff”), and Defendant MEAN, LLC (“Defendant”). Plaintiff and Defendant may collectively be referred to herein as “the Parties.” 1. RECITALS WHEREAS the case captioned above is one of six related cases filed in the Erie County Supreme Court (collectively referenced as the “Erie County Actions”). References to the Erie County Actions shall include, without limitation, all existing and potential claims, demands, actions, causes of action, liabilities, damages, costs, expenses, and controversies of every kind and nature—whether known or unknown, asserted or unasserted—arising prior to the date of execution of this Release (“Effective Date”), including all possible appeals, and any claims that were or could have been asserted by Plaintiff in the Erie County Actions or that relate in any way to the facts alleged therein; WHEREAS Plaintiff, together with the related Erie County Actions, filed complaints against Defendant alleging claims of, among other things, negligent advertising and marketing, violations of New York General Business Law §§ 349-350, negligent infliction of emotional distress, wrongful death, and public nuisance, and the Erie County Actions are pending in the Erie County New York State Supreme Court following the July 25, 2025 decision from the Appellate Division, Fourth Department; WHEREAS, Plaintiff and Defendant appeared for and reached certain agreements at mediation on September 29, 2025, in accordance with the binding mediation agreement, dated October 1, 2025, involving Mediator Dan Cavarello of Sugarman Law Firm, LLP; WHEREAS, to avoid the uncertainty and expense of further litigation, Plaintiff and Defendant desire to resolve fully and finally all issues and disputes between them involving the matters alleged in the Erie County Actions, without any admission of liability under the terms set forth below; WHEREAS, Plaintiff, together with the plaintiffs in the related Erie County Actions, entered into a binding Mediation Agreement, dated November 17, 2025, involving retired Judge Eugene Fahey; WHEREAS, the Parties acknowledge and incorporate by reference that certain global Stipulation of Settlement, dated February __, 2026 (“Stipulation”), entered into by Plaintiffs’ counsel and Defendant in the Erie County Actions, with the understanding that nothing in this individual Release is intended to modify, amend, limit, or expand the terms of the global Stipulation except as expressly necessary to implement Plaintiff‑specific obligations, releases, covenants and acknowledgements under this individual Release, including but not limited to (i) acknowledging Plaintiff’s specific settlement allocation, (ii) effectuating Plaintiff’s individual release of claims, and (iii) imposing any other Plaintiff‑specific duties, acknowledgments, representations, or warranties required to render this individual Release fully enforceable; WHEREAS, all terms, conditions, and obligations set forth in the Stipulation remain in full force and effect and are not altered, waived, or superseded by this Release, and, in the event of any inconsistency, the Stipulation shall control except with respect to the Plaintiff‑specific terms stated herein; and WHEREAS, Plaintiff and Defendant agree that all recitals set forth above are hereby incorporated by reference as if fully stated herein and shall form an integral part of this Release. NOW THEREFORE, in consideration of the mutual promises contained herein and for other good and valuable consideration as is more fully described below, the Parties hereby stipulate and agree as follows: 2. SETTLEMENT TERMS a. Consideration Amount. FOR CONSIDERATION of the amount allocated to Plaintiff in Addendum A to the November 17, 2025 Mediation Agreement signed by Plaintiffs’ counsel and retired Judge Eugene Fahey (“Allocated Amount”), to be distributed to Plaintiff solely from the funds paid by Defendant pursuant to the Stipulation. Plaintiff acknowledges and agrees that Defendant has fully satisfied all of its monetary obligations under the global settlement as set forth in the Stipulation and Defendant owes no additional payments of any kind to Plaintiff. Plaintiff further acknowledges that Defendant has no role in determining, influencing, controlling, or allocating the amounts distributed to individual plaintiffs—including the amount allocated to Plaintiff—as all allocations are made pursuant to the binding Mediation Agreement, dated November 17, 2025, involving retired Judge Eugene Fahey for which Defendant was not a party. Accordingly, Plaintiff expressly waives any claim, challenge, or demand that Defendant should have paid more money, contributed additional funds, or altered, influenced, or increased the allocation assigned to Plaintiff. Any dissatisfaction with, or dispute regarding, the Plaintiff’s allocated amount shall not form the basis of any claim against Defendant, and all such claims—whether known or unknown, asserted or unasserted—are fully and irrevocably waived. Any dispute regarding allocation shall not delay or affect the enforceability of this Release. b. General Release. Plaintiff hereby releases Defendant and its respective owners, shareholders, members, managers, heirs, executors, administrators, personal representatives, successors, assigns, insurers, reinsurers, officers, employees, agents, representatives, attorneys, affiliates, and any entity to which Defendant and/or its insurer(s) would or could owe common law or contractual indemnification (hereinafter collectively referred to as the “Released Parties”), jointly and severally, of and from any and all existing and potential claims, demands, actions, causes of action, liabilities, damages, costs, expenses, and controversies of every kind and nature, whether known or unknown, asserted or unasserted, arising prior to the Effective Date and including all possible appeals in connection with the Erie County Actions. This general release shall be comprehensive and unconditional, and shall extend to any claims that were or could have been asserted in the Erie County Actions or that relate in any way to the facts alleged therein. Defendant agrees and understands that there are other defendants in the Erie County Actions that are not a party to this Release and that plaintiffs in the Erie County Actions will continue to assert claims against those other remaining defendants, not to include Defendant, following execution of this Release. c. Court Approval. The Parties recognize and acknowledge that court approval may be a requirement for Plaintiff to enter into this Release, and for it to fully take effect. Plaintiff will work diligently to submit necessary documents to the court. If the Court at any time denies this Release or requires changes be made to it, the Parties understand that this will cause a delay. Any delay or failure to obtain approval shall not impose additional obligations on Defendant beyond those set forth in the Stipulation and this Release. d. Dismissal. Within the time period set forth in the Stipulation, Plaintiff shall file with the Erie County Supreme Court a Stipulation of Discontinuance with prejudice in the corresponding Erie County Action, dismissing with prejudice all claims set forth, or that could or would have been brought against Defendant, and serve copies on all counsel of record. Plaintiff expressly authorizes counsel of record for Plaintiff and/or Defendant to file such Stipulation of Discontinuance with prejudice with the Erie County Supreme Court. e. Full Accord and Satisfaction.

1. It is expressly understood and agreed that the acceptance of the Allocated Amount is a full accord, satisfaction, extinguishment, and bar of the claims and causes of action arising out of or relating to the corresponding Erie County Action, whether or not asserted therein, and that all agreements and understandings of the Parties are fully and completely expressed herein. 2. The Parties understand and agree that the Stipulation and this Release are the compromise of disputed litigation and payment made herein is not an admission of liability by Defendant. Defendant expressly denies any liability to Plaintiff, and neither this Release nor any consideration given hereunder is to be construed as an admission of liability, express or implied, on the part of Defendant and the Released Parties. 3. It is the purpose and intention hereof that Defendant and the Released Parties shall not, either directly or indirectly, under any form of action or proceeding, present or future, be liable for or required to make any further payment of any monies in any way, to any party, person, or entity, arising out of or relating to, in any way, the matters released by this Release. Plaintiff irrevocably covenants to refrain from, directly or indirectly, asserting or aiding the assertion of any claim or demand, or commencing, instituting, or causing to be commenced or instituted, any proceeding of any kind against Defendant or the Released Parties (or aiding the conduct of any such proceeding brought by any other entity or person), based upon or relating to any matters released hereby. 4. Plaintiff acknowledges that no party induced them to make this settlement or to release Defendant and the Released Parties; that in determining the amount of settlement, there has been taken into consideration not only Plaintiff’s alleged ascertained claims, injuries, disabilities, and damages, but also the possibility that the injuries allegedly sustained may be permanent and progressive, greater or more extensive than is now known, anticipated or expected, and recovery therefrom indefinite and uncertain so that consequences not anticipated may result. Plaintiff therefore agrees that this release shall apply to all unknown and unanticipated injuries and damages resulting from and/or relating to the Erie County Actions as well to those now known or anticipated. 5. Plaintiff acknowledges and agrees that this Release is final and irrevocable. Plaintiff shall not seek to reopen, rescind, unwind, challenge, or otherwise contest the validity, enforceability, or scope of this Release or the Stipulation, whether on the basis of allocation, dissatisfaction with the amount received, newly discovered facts, or any other reason. No dispute regarding the Plaintiff’s allocated share shall delay, impair, or affect the enforceability of this Release. In the event Plaintiff attempts to pursue any released claim, Defendant shall be entitled to assert this Release as a complete bar and to seek enforcement in any court of competent jurisdiction.

f. Non-Disparagement and Press. Plaintiff expressly acknowledges and agrees to comply with the non-disparagement terms set forth in Section II. J. of the Stipulation. g. No Admissions. The Parties agree and understand that the facts and terms of this Release, including all negotiations, discussions, drafts, and proceedings in connection with this Release and any omissions or acts performed in connection with this Release shall not constitute admission or evidence of wrongdoing or liability. h. Enforcement. For the avoidance of doubt, nothing in this Release, waives or prejudices the rights of any Party to enforce this Release. i. Liens.

1. General Liens. Plaintiff acknowledges and agrees that it is their responsibility to reimburse any lienholders for any payments made by any valid lienholders on behalf of any of the Plaintiff, and that neither Defendant nor the attorneys for any party are responsible for such reimbursement. Plaintiff understands that they are responsible for negotiating any such lien directly with any person or entity making a valid lien claim, and that Defendant has no obligation to do so on Plaintiff’s behalf, nor shall Defendant have any additional obligations to make payments to Plaintiff directly, through, or to any insurer claiming by or through Plaintiff. Defendant takes no position whatsoever on the validity or amount of any such lien that may be asserted. 2. Medicare / Medicaid Lien Satisfaction and Reporting Compliance. Plaintiff expressly represents, warrants, and agrees that there are no outstanding Medicare, Medicaid, or other state or federal liens against any recovery of any kind or character. In the event Plaintiff applied for or received any benefits from Medicare, the Parties to this Release believe that any rights or interests Medicare may have in the within settlement have been considered pursuant to 42 CFR § 1395y(b)(3)(A) and it is not the intention of the Parties to shift responsibility of future medical benefits to Medicare. Plaintiff shall be responsible for satisfying any liens for Medicare payments associated with the alleged injuries and/or treatment. Plaintiff hereby agrees to indemnify and hold harmless Defendant, its insurer(s) and the Released Parties, from any and all liability for any outstanding or future liens or expenses held by any state or federal governmental agency or entity, fines or civil penalties (including but not limited to fines for civil penalties related to the provision of false or inaccurate information from Plaintiff regarding existing or future Medicare, Medicaid, or other state or federal liens), and costs and/or expenses incurred in the past or which might be incurred in the future arising from or related to the Erie County Actions. In the event Plaintiff is eligible to receive Medicare benefits, Plaintiff agrees to provide Defendant with a completed and properly executed original CMS Compliance Form simultaneously with executing this Release (Exhibit B). Plaintiff further agrees to cooperate with Defendant to provide any supplemental information in the future which are necessary to satisfy Defendant’s reporting obligations, if any, regarding Medicare, Medicaid, or other state or federal programs or liens. 3. Tax Responsibility. Plaintiff acknowledges and agrees that Plaintiff is solely responsible for any and all federal, state, and local taxes, assessments, withholdings, penalties, or interest, if any, that may be owed on account of the proceeds described herein. Defendant makes no representations concerning the tax consequences of this settlement. Plaintiff agrees to indemnify and hold Defendant and the Released Parties harmless from any claim, liability, or expense (including attorneys’ fees) arising from or relating to any tax obligation associated with the settlement proceeds.

j. Remaining Provisions. The Parties hereby incorporate by reference (as applicable to this Release), the following Sections of the Stipulation: Section II. M. through and including Section II. Q. k. Entire Agreement. Subject to the Stipulation, this Release contains the entire understanding among the Parties with respect to the terms contemplated hereby and supersedes any and all prior and contemporaneous agreements, understandings, inducements, or conditions, express or implied, oral or written, among the Parties. Should any provision of this Release be declared or determined by a court to be illegal, invalid, void or unenforceable, the remaining provisions of the Release will not be affected and said illegal, invalid, void or unenforceable provision will be modified or amended to render the remainder of the Release enforceable. This Release may not be amended except by an instrument in writing signed on behalf of the Parties to this Release. This Release merges and supersedes all prior discussions, agreements, understandings, representations, conditions, warranties, covenants, and all other communications, whether oral or written, between and among the Parties relating to the subject matter hereof. l. Communications. All notices, reports, requests, and other communications pursuant to this Release shall be in writing and shall, unless expressly provided otherwise herein, be given by electronic mail addressed as follows:

1. If to Plaintiff in the Erie County Action, to the following: o Alison Barnes (abarnes@everytown.org) o Eric Tirschwell (etirschwell@everytown.org) 2. If to Defendant, to all of the following: o Christopher Renzulli (crenzulli@renzullilaw.com) o Peter V. Malfa (pmalfa@renzullilaw.com)

m. Knowing and Voluntary Assent and Entry Into Release. Plaintiff represents and warrants that Plaintiff is of sound mind, not under the influence of any substance, and fully competent to enter into this Release. Plaintiff further represents that Plaintiff has carefully read this Release, understands all of its terms, had the opportunity to consult with counsel of Plaintiff’s choosing, and signs this Release freely and voluntarily, without coercion, duress, or undue influence. The Parties further acknowledge that they have entered this Release freely and voluntarily and upon due deliberation with the advice of counsel. The Release and all of its terms shall be construed as if mutually drafted with no presumption of any type against any party that may be found to have been the drafter. This Release may be executed in counterparts, each of which shall be deemed to be an original, but all of which, taken together, shall constitute one and the same agreement. n. General Provisions.

1. Assignment. Plaintiff represents and warrants that no other person or entity has, or has had, any interest in the claims, demands, obligations, or causes of action referred to in this Release; that they have the sole right and exclusive authority to execute this Release and receive the sums specified in it; and that they have not sold, assigned, transferred, conveyed or otherwise disposed of any of the claims, demands, obligations, or causes of action referred to in this Release or contained in Plaintiff’s pleading(s) filed in the corresponding Erie County Action. Each of the covenants contained in this Release shall be binding upon and shall inure to the benefit of the Parties and the Released Parties, their respective owners, shareholders, members, managers, directors, officers, employees, agents, affiliates, attorneys, insurers, representatives, servants, predecessors, successors, heirs and assigns of each of the Parties hereto. 2. Indemnification and Hold Harmless. Plaintiff agrees to resolve any dispute with any insurer or other person or entity (including but not limited to medical expenses, physician and hospital bills, Medicare, Medicaid, and/or any other state or federal agency) over any past, present or future lien, claim or monies owed and attorneys’ fees incurred by reason of Plaintiff’s alleged injuries, illness, disease, or condition, whether now existing or which may exist in the future, arising out of or from the Erie County Actions. Plaintiff agrees that they are solely responsible for repayment of any such liens. Plaintiff also agrees that in the event that any person or entity asserts a claim that he, she or it is entitled to payment of a claim or a lien by Defendant, then Plaintiff will indemnify, protect, defend and hold harmless Defendant, its insurer(s) and the Released Parties, including but not limited to their respective owners, shareholders, members, managers, directors, officers, agents, affiliates, attorneys, employees, representatives, servants, predecessors, successors, heirs, assigns, and any others acting on their behalf, from and against any and all claims and demands, legal fees, costs or expenses, judgment or settlement associated with any such claim or lien, including, but not limited to, medical provider liens, insurer liens, Medicare and/or Medicaid liens, attorneys’ fees incurred by Plaintiff or other expenses incurred by or on behalf of Plaintiff, whether past or future, which arises out of or relates in any way to the Erie County Actions. Plaintiff agrees to cooperate fully with Defendant in executing any additional documents and providing any information reasonably necessary to effectuate or enforce this Release, fulfill reporting obligations, or resolve any issues relating to liens, tax forms, or regulatory compliance. Plaintiff agrees to respond promptly to Defendant’s reasonable requests for such cooperation. 3. Singular/Plural and Gender. The use of the singular form of any name, noun or pronoun in this Release shall include, where appropriate, the plural thereof; the use of the masculine gender in this Release shall include, where appropriate, the feminine. 4. Electronic Signature. If Plaintiff executes this Release electronically (e.g., via DocuSign, etc.), Plaintiff consents to execute this Release using Electronic Signatures subject to the provisions of the Electronic Signatures in Global and National Commercial Act (E-SIGN Act), the Uniform Electronic Transmissions Act (UETA) and New York State Technology Law Article 3, N.Y. Tech. Law §§ 301-309, and to be legally bound by the Release’s terms and conditions. Plaintiff’s Electronic Signature constitutes Plaintiff’s signature, acceptance, and agreement, and is the legal equivalent of Plaintiff’s manual signature as if actually signed in writing. Plaintiff also agrees that no certification authority or other third-party verification is necessary to validate Plaintiff’s Electronic Signature and that the lack of such certification or third-party verification will not in any way affect the enforceability of Plaintiff’s Electronic Signature or this Release. Plaintiff further agrees that fully executed copies of this Release transmitted electronically in Portable Document Format (PDF) by DocuSign, or an equivalent, shall constitute one and the same instrument and be fully binding with full legal force and effect, and Plaintiff waives any rights he or she may have to object to such treatment.

AGREED TO: I affirm this ___ day of ______, 2026, under the penalties of perjury under the laws of New York, which may include a fine or imprisonment, that the foregoing is true, except as to matters alleged on information and belief and as to those matters I believe it to be true, and I understand that this document may be filed in an action or proceeding in a court of law. By: _______________________________ [PLAINTIFF NAME]

MM slash DD slash YYYY
This field is hidden when viewing the form
This field is hidden when viewing the form
This field is hidden when viewing the form
MM slash DD slash YYYY

      Please note that the settlements require that you not “disparage” MEAN LLC, Vintage Firearms LLC, Paul Gendron, and Pamela Gendron. This means that you must avoid making public statements to reporters or posts on social media that criticize MEAN LLC, Vintage Firearms LLC, Paul Gendron, and Pamela Gendron. You also must avoid publicly criticizing anyone associated with MEAN LLC and Vintage Firearms LLC, such as its owners.
      If you are contacted by a reporter asking for a comment on MEAN LLC, Vintage Firearms LLC, Paul Gendron, Pamela Gendron or the settlements, you should contact your attorneys before offering any comment.