SETTLEMENT AGREEMENT AND

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Shared by: Earl Simmons
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OEC GROUP OEC FREIGHT (NY) INC. 145-64 156th Street, Jamaica, NY 11434 Tel: (718) 5277171 Fax: (718) 5277077 E-Mail: all.jfk@oecgroup.com SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS (United States of America) BILL OF LADING NO.: ________________ For and in consideration of the sum of _______________, I/we release and forever discharge _______________, and all other parties whatsoever, his/her/their principals, agents, heirs, representatives, assigns, and insurance carriers, their agents and employees from any and all rights, claims, demands, and damages of any kind, known or unknown, existing or arising in the future, resulting from or related to personal injuries, death, delay, commercial loss or property damage, arising from or in connection with a shipment of "___________" aboard the M/V ) to the Port of ________ on or about ________________. In further consideration of the settlement amount received, all claim rights are assigned to the payor. To procure payment of this sum, I/we declare: I/we am/are more than eighteen (18) years of age; further, that no representations about the nature and extent of said injuries, losses or damages made by any attorney, or agent of any party released, nor any representations regarding the nature and extent of legal liability or financial responsibility of any of the parties released, have induced me/us to make this settlement. I/we waive all rights which I/we now or may have by virtue of Section 1542 of the California Civil Code, or similar law of the jurisdiction where this agreement is entered upon which reads: "A general release does not extend to the claims which a 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.” This release shall not destroy or otherwise affect the rights of persons on whose behalf this payment is made to pursue any legal remedies they may have against any other persons. I/we understand this is a compromise settlement of all my/our claims of every nature and kind whatsoever arising out of the incident or transaction referred to above, but is not an admission of liability. I/we understand that this is all the money or consideration I/we will receive from the above described parties as a result of this incident or transaction. I/WE HAVE READ THIS RELEASE AND UNDERSTAND IT. DISMISSAL OF LAWSUIT: I/we understand that in exchange for this settlement, and as additional consideration therefore, I/we agree to dismiss forever, that certain lawsuit entitled _______ filed in the ________ Court, on or about _________ under Case Number ____________. FOR YOUR PROTECTION PLEASE NOTE THE FOLLOWING: Any person who knowingly presents false or fraudulent claim for the payment of a loss is guilty of a crime and may be subject to fines and confinement in state prison. Signed this day of , 2001, at . _________________________________ _______________________________ (Name of Company) By Its:____________________________ of Company) By Its:__________________________ (Name

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