Filed by Mo Hugh at 3/2/2012 12:20PM

Defendants Hugh H.Mo, Kao Sung Liu and Gina Hiu-Hung Liu, by and through undersigned counsel, hereby consent to the partial dismissal of their pending Motion for Sanctions, pursuant to Fed.R.Civ.P.Rule 11, only as against attorney Ming Hai, Esq., with prejudice, and without costs, expenses or attorneys' fees to any of the parties as against the other, and pursuant to the attached Agreement of Settlement, with the settlement amount redacted.

Dated: New York, New York
       March 2, 2012

                                                           The LAW OFFICE OF Hugh H MO

                                                           The LAW OFFICE OF MING HAI, P.C.

SO ORDERED:
HONORABLE JAMES C. FRANCIS
U.S. MAGISTRATE JUDGE

    This Settlement Agreement and Release and the attached exhibits hereto, (the "Settlement Agreement"), is made and entered into by and between KAO SUNG LIU and GINA HIU-HUNG LIU ("the LIUS") and HUGH H.MO ("MO") on the one hand, (collectively, "Defendants"), and MING HAI, ("HAI"), on the other hand. The Defendants and HAI are also hereinafter referred to as the "Parties."

     WHEREAS, on behalf of Plaintiff Sang Lan, as attorney of record, HAI instituted an action against the Defendants and others, in the matter of Dang Lan v. AOL Time Warner, Inc., et.a;., Index No. 11-CV-2870 (LBS)(JCF), in the United States District Court for the Southern District of New York, (the "Action");

    NOW, THEREFORE, in consideration of the mutual covenants, benefits, promises and agreements contained herein, and other good and valuable consideration, the receipt, adequacy and sufficiency of which are hereby acknowledged, the Parties, intending to be legally bound, represent, covenant and agree as follows:

    1. Payment. On or before March 7, 2012, HAI shall pay the sum $5,000 by attorney or bank check made payable to "KAO SUNG LIU, GINA HIU-HUNG LIU, and HUGHH.MO," (the "Payment").

    2. Signed Acknowledge of Wrongdoing. On or before March 2, 2012, HAI will execute an Acknowledgement of Wrongdoing in both Chinese and English in the form attached hereto as Exhibits "A" and "B", (the "Acknowledgments").

    3. Dismissal of the Action. On or before March 2, 2012, MO, on behalf of the Defendants, and HAI will execute a joint "Stipulation of Partial Dismissal" in the form attached hereto as Exhibit "C", dismissing with prejudice Defendants' pending Rule 11 Motion for Sanctions as against HAI only, (the "Rule 11 Motion"), such that each party bears his or its own costs, fees and expenses. The joint Stipulation will be held in escrow by MO pending receipt of the Payment by HAI.

    4. Failure to Transmit Payment. In the event that the Payment is not received by March 7, 2012, the Defendants shall have the rights to exercise any remedies which may be available to them. In that event, unless and until the Defendants receive the Payment, neither party shall be bound by any of the provisions of this Settlement Agreement.

    5. Mutual Releases.

    Upon HAI's full satisfaction of his obligations under this Settlement Agreement:

    a. The Defendants, together with their related companies or firms and assigns, or employees thereof, (collectively, the "Defendant Releasors"). for good and valuable consideration, the sufficiency of which is hereby acknowledged, hereby release and forever discharge HAI, together with his related companies and assigns, and any officers, directors or employees thereof, (collectively, the "Defendants Releasees") from any and all rights, interests, kind and nature, in law or in equity, known or unknown, suspected and unsuspected, fixed or contingent, anywhere in the world, arising out of or relating to events occurring through the effective date of this Settlement Agreement, including without limitation all claims arising out of or relating to Defendants' pending Rule 11 Motion and any other claims which have been or could have been asserted in Defendants' pending Rule 11 Motion and any potential claims by Defendants against HAI for malicious prosecution or attorney misconduct asserted in state court or in disciplinary proceedings. The Defendant Releasors represent and warrant that there has been no assignment or other transfer of any interest in any claims or potential claims against the Defendant Releasees that are covered by the Releases contained in this paragraph. Notwithstanding anything else in this Settlement Agreement that might be construed to the contrary, this Release does not extend to the Parties' continuing rights and obligations under this Settlement Agreement. Notwithstanding anything else in this Settlement Agreement that might be construed to the contrary, this Release does not extend to any claims between Sang Lan and the Defendants in this Action or in any other action.

    b. HAI, along with his related companies or firms and assigns, and any officers, directors or employees thereof, (collectively, the "Hai Releasors"), for good and valuable consideration. the sufficiency of which is hereby acknowledged. hereby release, and forever discharge Defendants, together with their predecessors, successors, parents, subsidiaries, affiliates, related companies and assigns, and any officers, directors or employees thereof, (collectively, the "Hai Releasees"), from any and all rights, interests, claims, demands, causes of action, indebtedness, damages, liabilities and obligations of every kind and nature, in law or in equity, known and unknown, suspected and unsuspected. fixed or contingent, anywhere in the world, arising out of or relating to events occurring through the effective date of this Settlement Agreement. The Hai Releasors represent and warrant that there has been no assignment or other transfer of any interest in any claims or potential claims against the Hai Releasees that are covered by the Releases contained in this paragraph. Notwithstanding anything else in this Settlement Agreement that might be construed to the contrary, this Release does not extend to the Parties' continuing rights and obligations under this Settlement Agreement. Notwithstanding anything else in this Settlement Agreement that might be construed to the contrary, this Release does not extend to any claims between Sang Lan and the Defendants in this Action or in any other action.

    6. No Admission. Apart from the statements contained in the Acknowledgments, nothing herein is intended, nor shall be construed as, an explicit or implicit admission of liability or finding of wrongdoing by any of the Parties.

    7. Representations, Warranties, Covenants and Additional Provisions.

    a. Each of the Parties represents and warrants that (i) the persons signing this Settlement Agreement have full authority and representative capacity to execute this Settlement Agreement on behalf of themselves and all other persons. corporations or entities for whom they purport to act as stated herein, and (ii) this Settlement Agreement has been duly executed and constitutes the valid and binding obligation of the Party signing such Settlement Agreement.

    b. This Settlement Agreement shall become valid when executed by all Parties hereto. This Settlement Agreement and the obligations provided hereunder, including all questions of enforcement and interpretation hereof, and all controversies arising hereunder, shall be governed and construed in all respects by the law of the State of New York, without regard to its choice of law or conflicts of laws provisions and/or any principles of choice of law or conflicts of law. Any action arising out of or relating to this Settlement Agreement shall be heard and determined exclusively in the County of New York, State of New York. For purposes of enforcement and interpretation of this Settlement Agreement, the Parties hereby submit to personal jurisdiction and venue in the courts of the State of New York and federal courts located in the Southern District of New York, and waive all forum non conveniens claims and/or defenses. The parties agree that any dispute relating to this agreement may be heard and tried by Magistrate Judge James C. Francis, if he is willing and available to hear such dispute.

    c. The Parties warrant and represent that they have read this Settlement Agreement, that they have conferred with their attorneys concerning this Settlement Agreement and the terms: and conditions hereof, and that they fully understand the terms, conditions, requirements and effect of this Settlement Agreement.

    d. This Settlement Agreement constitutes the entire agreement· and understanding between the Parties with respect to the settlement of any and all disputes between them. This Settlement Agreement supersedes all prior agreements, arrangements and understandings (written or otherwise) between the Parties with respect to the resolution of any such disputes, and no representation or warranty, oral or written, express or implied, has been made by or relied upon by any of the Parties hereto, except as expressly contained herein. This Settlement Agreement may not be modified, amended, altered or rescinded except by a writing executed and signed by all the Parties. Any waiver of any term or condition of this Settlement Agreement must be in writing and shall only be effective for the specific period and Purpose expressly stated therein.

    e. The Parties acknowledge and agree that, in deciding to execute this Settlement Agreement, each has relied entirely upon its own respective judgment and has entered into the Settlement Agreement in the exercise of such judgment in the absence of duress or coercion. Each Party has had the opportunity to consult with counsel of its own choosing. Each Party represents that it has the authority to enter into this Settlement Agreement and that such Settlement Agreement does not violate any order, writ, injunction, decree, judgment, ruling, law, rule or regulation of any court or governmental authority applicable to such Party. or require any consent, approval or authorization of, or notice to, or declaration, filing or registration with, any governmental or regulatory authority.

    f. The Parties hereto agree that the terms and language of this Settlement Agreement were the result of negotiations between the Parties and, as a result, there shall be no assumption that any ambiguities in the Settlement Agreement shall be resolved against any Party. Any controversy over the construction of this Settlement Agreement shall be decided without regard to the events of authorship or negotiation.

    8. No Confidentiality. With the exception of the Settlement Amount, this Settlement Agreement may be made publicly available and is subject to no restrictions as to Confidentiality.

    9. Effect of Settlement. This Settlement Agreement shall completely satisfy HAI's liability with respect to Defendants' pending Rule 11 Motion for Sanctions against HAI.

    IN WITNESS WHEREOF, the Parties have executed this Settlement Agreement with the intent that this Settlement Agreement is and shall have the effect of a binding agreement under law as of the day of the last signature by a Party below. The Parties agree that this Settlement Agreement may be executed in multiple counterparts and may be executed by facsimile signature, each of which shall be deemed an original and all of which taken together shall constitute one and the same instrument.

  MING HAI, ESQ.

  HUGH H. MO, ESQ.
  KAO SUNG LIU
  GINA HIU-HUNG LIU

 I, Hai Ming, an attorney duly admitted to practice in the courts of the State of New York, hereby respectfully and sincerely apologize to Attorney Hugh H. Mo, Maria Mo, K.S. Liu, Gina Liu, Winston Sie. and their families and associates for my misconduct against them with respect to the matter of Sang Lan v. AOL Time Warner, Inc., et al. that I filed in U.S. District Court Southern District of New York.

 I profoundly regret that I have caused severe and irreparable harm to the Lius and Mr. Mo by filing salacious complaints against them that included clearly frivolous claims based upon causes of action that do not exist under New York law or completely fail to allege even the basic elements of the relevant cause of action, including bizarre damage allegations and claims for civil conspiracy, defamation by Mr. Mo, prima facie tort, intentional/negligent infliction of emotional distress, as well as several of the alleged grounds for breach of fiduciary duty.

 I am also very sorry for making baseless accusations against the Lius and Mr. Mo on the internet and through the media, including the allegations of sexual abuse, in order to coerce them to settle the lawsuit, which I acknowledge have caused them to suffer personally and publicly.

 In view of my serious wrongdoing and misconduct herein, I am grateful to the Lius and Mr. Mo for their generosity to permit me to offer this heartfelt apology (and pay certain monies) in full settlement of the travesties that I have caused to them.

 For these reasons, I beg them to forgive me.

 THE LAW OFFICE OF MING HAI, P.C.

By: Ming Hai, Esq. 
36-09 Main Street, Suite 7B 
Flushing, New York 11354
(718) 445-9111
(718) 445-5424 (f)

 翻译 （基于HQ网友的翻译和中文版，略有改动）

    本人海明，是纽约州执业律师，在此向莫虎律师、张燕、刘国生、谢晓虹和薛伟森以及他们的家人和合伙人致以真诚的道歉，事关本人向纽约南区美国联邦法院所递交的桑兰诉AOL时代华纳等一案中对他们的不端行为。

    对于给刘谢夫妇和莫虎先生所造成的严重的不可弥补的伤害我深表遗憾。在我提交的煽动人心的诉状中，含有明显轻浮的指控。这些指控基于按纽约州法律不存在的控罪，甚至连最起码的基本法律元素都不具备。其中包括荒诞离奇的损害和民事共谋指控，指责莫虎先生诽谤，明显侵权，故意及轻忽造成的精神重创，以及好几个违反信托义务的指控理由。

    由于我在互联网上和媒体中对刘家及莫先生进行了毫无根据的指控，包括声称性侵，来迫使他们庭外和解，令他们在个人生活和公众场合承受痛苦，对此我非常抱歉。

    鉴于我的上述错误和不端行为，我感激刘谢夫妇和莫虎先生的宽宏大量。他们允许我给予这衷心的道歉（和支付一定的金钱），用以完全平息我对他们造成的悲剧。

    我求他们原谅我。