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expenses, for attorneys fees, costs, or interest, for
loss of services, for loss of support, for loss of
association, companionship, love and affection, and for
any and all other additional losses incident to the
relationships of husband and wife or parent and child,
whether at law or in equity, in any manner arisen,
arising or to grow out of the following:
1) an automobile accident * * * more specifically
described in that certain Honolulu Police
Department Motor Vehicle Accident Report No. C-
30064;
2) the conduct, acts, or failures to act, or refusals
to act on the part of RELEASEE, * * * in connection
with the investigation, claim handling, or settlement
of any claim arising out of or in connection with said
Accident;
3) any alleged neglect or refusal by RELEASEE to pay
any benefit or recognize any obligation under any
policy of insurance issued to any party and arising out
of said Accident;
4) the conduct, acts, or failures to act, neglect, or
refusals to act on the part of RELEASEE, or any of its
employees, agents, officers, directors, predecessor or
successor entities, or their respective attorneys, in
connection with the writing, amendment, revision,
issuance, promulgation, sale, and/or marketing of any
policy of insurance;
any of which said Accident, conduct, acts, failures or
refusals to act, or neglect may have resulted in injuries or
damages to RELEASOR, as more specifically set forth in that
certain lawsuit in the United States District Court for the
District of Hawaii, and entitled John Marsh v. Travelers
Insurance Company, et al., Civil No. 89-00262-HMF.
After payment of attorney's fees and costs, petitioner's share of
the settlement proceeds amounted to $68,102.70. Petitioner
negotiated the settlement check for cash on December 15, 1989.
No portion of the settlement proceeds was deposited into any bank
account maintained by petitioner. Respondent's notice of
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