STIPULATION AND ORDER FOR RELEASE OF FUNDS DEPOSITED BY AMERICAN NATIONAL INSURANCE COMPANY PLUS ACCRUED INTEREST; DISCHARGE OF PLAINTIFF; AND DISMISSAL

WILLIAM ALSUP, District Judge.

Plaintiff American National Insurance Company ("ANICO"), Defendant Estate of Teresa P. Hughes ("Defendant Hughes"), and Defendant Frank Staggers, Jr., as Trustee of the Frank E. Staggers, Sr., M.D. Revocable Living Trust and as Executor of the Estate of Frank E. Staggers, Sr., Alameda County Superior Court Case No. RP15769612 ("Defendant Staggers"), by and through their respective counsel, stipulate as follows:

1. On August 17, 2015, ANICO filed in this action its "First Amended Complaint for Interpleader and Declaratory Relief." The subject of the First Amended Complaint is WealthQuest 5 Citadel Single Premium Annuity issued by ANICO having policy no. 14863570 ("Annuity").

2. Defendant Hughes and Defendant Staggers (collectively, "Defendants") filed their respective Answers to the First Amended Complaint.

3. On October 29, 2015, the Honorable William Alsup issued the "Order on Motion By Plaintiff American National Insurance Company To Deposit Annuity Benefit Money In InterPleader; Request The Court Deposit Funds In Interest-Bearing Account" ("Deposit Order").

4. On December 29, 2015, in accordance with the Deposit Order, ANICO deposited with the United States District Court, Northern District of California, the sum of $118,862.47 representing the Annuity principal and accrued interest thereon.

5. On February 5, 2016, the parties participated in a settlement conference presided over by Magistrate Judge Donna M. Ryu, at which time they settled all matters between them. In accordance with that settlement, the parties stipulate and agree as follows:

a. Each Party to Bear Own Fees and Expenses. The parties shall each bear their own attorney's fees and expenses in connection with this action, the settlement and the Annuity;

b. Mutual Release of Claims. The parties, and each of them, for themselves and on behalf of their respective present and former agents, and all those claiming by, through, under or in concert with them or any of them (collectively "Releasing Parties"), hereby absolutely, forever and fully, generally and specifically, release and discharge each other and each of the other parties respective present and former agents, and each of them, (collectively the "Released Parties") from any and all claims, contentions, rights, debts, liabilities, costs, expenses (including, but not limited to, attorneys' fees), of any kind whatsoever (hereinafter referred to as "Claims"), whether based upon contract, tort, statute or any other legal or equitable theory of recovery, and whether known or unknown, with respect to, pertaining to, or arising from any matters, acts, omissions, events, conduct or occurrences at any time prior to February 5, 2016, including, without limiting the generality of the foregoing provisions, any and all causes of action or Claims referred to, or based on, ANICO's First Amended Complaint, each of the Defendants' respective Answers, and with respect to the Annuity. This Paragraph is referred to as the "General Release".

c. Release of Unknown Claims. Releasing Parties, and each of them, acknowledge that they, or any of them, may hereafter discover Claims and/or facts now unknown or unsuspected, or in addition to, or different from, those which Releasing Parties now know or believe to be true with respect to the General Release. Nevertheless, Releasing Parties, and each of them, intend by the General Release to release fully, finally, and forever all Claims released hereby.

d. Payment of Annuity Proceeds. The funds deposited by ANICO with the United States District Court, Northern District of California, including any accrued interest thereon, shall be paid out as follows: 55% to Frank Staggers, Jr., as Trustee of the Frank E. Staggers, Sr., M.D. Revocable Living Trust, and 45% to Deirdre Hill and Vincent G. Hughes, as co-executors of the Estate of Teresa P. Hughes.

e. ANICO Discharge. ANICO is entitled to a judgment of discharge in interpleader in its favor in this action and as to the Defendants.

TRIAY LAW OFFICE Date 3/14/16 Charles A. Triay Paul D. Epstein Counsel for Frank Staggers, Jr. LAW OFFICE OF STEVEN ROOD Date 3/11/16 Steven Rood Counsel for Deirdre Hill and Vincent G. Hughes WILSON ELSER MOSDOWITZ EDELMAN & DICKER LLP Date 3/10/16 Francis J. Torrence Counsel for American National Insurance Company

ORDER

Based on the foregoing Stipulation, and good cause appearing, IT IS HEREBY ORDERED that:

1. ANICO is discharged in interpleader in its favor and as to the Defendants.

2. The Clerk of the United States District Court, Northern District of California, shall pay the funds deposited by American National Insurance Company on December 29, 2015, including any accrued interest thereon, as follows:

a. To Frank Staggers, Jr., as Trustee of the Frank E. Staggers, Sr., M.D. Revocable Living Trust, $65,374,36 plus 55% of any interest accrued thereon; and

b. To Deirdre Hill and Vincent G. Hughes, as co-Executors of the Estate of Teresa P. Hughes, $53,488.11 plus 45% on any interest accrued thereon.

3. Upon distribution of the funds by the Clerk as provided in Paragraph 2, above, this action is DISMISSED WITH PREJUDICE.