Sam Ervin and Ella M. Ervin, et al. - Page 5




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          in pertinent part:                                                          
                    I fully understand that when I sign this Receipt                  
               and Release I will have surrendered and released all                   
               rights and claims which I now have, both known and                     
               unknown, against * * * United * * *; including, but not                
               limited to, claims for past, present, and future                       
               damages, indemnity, costs, attorneys fees, interest of                 
               all types, and damages of every other kind by whatever                 
               named called.                                                          
                     *      *      *      *      *      *      *                      
                    For the same consideration recited herein above, I                
               and my attorneys * * * agree that every aspect of this                 
               settlement shall remain confidential in every respect                  
               * * *.                                                                 
                    For the same consideration recited herein above, I                
               and my attorneys * * * agree that they will surrender                  
               every document of every type that has been produced to                 
               them or their clients by United * * * in any case                      
               * * *.                                                                 
                    For the same consideration recited herein,                        
               attorneys * * * hereby warrant that they have not                      
               heretofore and will not in the future transmit or                      
               convey in any manner the documents described in the                    
               preceding paragraphs to any third parties of any type.                 
               * * * Said attorneys further warrant that they have not                
               and will not in the future refer current or former                     
               policyholders of United * * * to any third parties for                 
               possible prosecution of any purported claims.                          
               The last paragraph of the settlement agreements states:                
                    I hereby acknowledge that all settlement amounts                  
               received are for damages that are compensatory in                      
               nature and that no payment was or will ever be paid to                 
               me for alleged punitive damages arising out of any                     
               claims which I asserted or could have asserted in this                 
               matter.                                                                
               In February 1994, petitioners gave their attorneys all of              
          their documents related to their claims against United.  All of             
          those documents were then shredded.  Petitioners and their                  





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