- 5 - 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 theirPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011