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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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Last modified: May 25, 2011