Document K6L00naBjLEoD50n9dYRy5OJN
LAW DEPARTMENT
CONFORMED COPY
RELEASE OF ALL DEMANDS
Dated: January , 1992
In consideration of ONE ($1.00) DOLLAR and other valuable consideration paid to Alice Warren, by Conoco Inc. (formerly known as Continental Oil Company, and hereinafter referred to as "Conoco"), the receipt and sufficency of which are hereby acknowledged, I, Alice Warren, hereby release and forever discharge the said Conoco, its officers, directors, employees, agents, insurers, successors, heirs, and assigns against whom claim has been made or may be made arising out of the events more particularly hereafter described in which John Warren was allegedly injured, of and from all causes of action and any and all claims, demands and liabilities whatsoever which against the Conoco and its officers, directors, employees, agents, insurers, successors, heirs and assigns, I now have or ever had at any time, including but not limited to, all claims that were or could have been asserted in the civil action entitled: Alice L. Warren. Administratrix of the Estate of John H. Warren. Deceased v. The Dow Chemical Company, et. al.. United States District Court, District of Massachusetts, Western Section, Civil Action No. 89-30201F, and more especially with respect to the alleged exposure of John Warren to vinyl chloride monomer produced or sold by Conoco
UCC 080554
which exposure allegedly took place during the course of John Warren7s employment with Monsanto Chemical Company at its facility located in Indian Orchard, Massachusetts over a period of years. This Release specifically includes all personal injury and losses of consortium or services, and consequences thereof, including pain and conscious suffering and, also, any damages or recoveries allowable under the wrongful death statute, M.G.L. c. 229, 1 et. sea.. and any injuries and losses which may exist but which, at this time, are unknown and unanticipated and which may develop at some time in the future, and all unforeseen developments arising from said known or unknown injuries and losses.
It is expressly understood and agreed that the acceptance of the above said amount and the other valuable consideration is in full accord and satisfaction of a disputed claim and that the payment of the said amount is not an admission of liability.
I have been represented by and received the advice of counsel in regard to the execution of this agreement.
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UCC 080555
IN WITNESS WHEREOF, Alice Warren as administratrix of the
Estate of John Warren and on behalf of herself individually
-JAhereunto sets her hand and seal this
day of January,
1992.
Signed in the presence of:
^t
7
Alice Warren
HAMPTON, ss.
COMMONWEALTH OF MASSACHUSETTS January /, , 1992
Then personally appeared the above-named Alice Warren and acknowledged the foregoing Release to be her free act and deed, as the administratrix of the Estate of John Warren and in her individual capacity, before me.
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My Commission Expires:
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UCC 080556