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* * * * * * *
3. * * * [Petitioner] hereby agrees and
promises * * * (3) that by entering into this
Settlement Agreement and General Release, she
is waiving any and all right[s] she may have
under the terms of the Consent Decree
respecting instatement or rights to any other
future class relief * * *
* * * * * * *
5. It is understood and agreed that this
is a full and final General Release applying
not only to all Claims which are presently
known, anticipated or disclosed to * * *
[petitioner], but also to all Claims which are
presently unknown, unanticipated, and
undisclosed to * * * [petitioner] and which may
have arisen prior to the date of execution of
this Settlement Agreement and General Release.
* * * [Petitioner] hereby waives any and all
rights or benefits which she may now have, or
may in the future have, under the terms of
Section 1542 of the California Civil Code,
which provides as follows:
A general release does not
extend to claims which the creditor
does not know or suspect to exist in
his favor at the time of executing
the release, which if known by him
must have materially affected his
settlement with the debtor.
* * * * * * *
7. It is understood and agreed that this
compromise settlement includes the compromise
settlement of any and all legal, evidentiary,
discovery, and document production issues
regarding Claim No. 554 * * *. The parties
further agree and understand that neither State
Farm nor * * * [petitioner] will bring any
motions, either individually or as part of the
class, relative to such Claim No. 554 issues *
* *
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Last modified: May 25, 2011