The Release as to the Settling Defendants provides:
The Releasing Plaintiffs release and covenant not to sue on each and every Claim, including, but not limited to, any Unknown Claim, that was advanced or could have been advanced in the Action, including, but not limited to: (a) claims relating to broker compensation, so-called “contingent commissions,” commissions paid on lineslips, binding authorities or open market placements, alleged overriders, alleged steering, and alleged bid-rigging arising from or related to the purchase or renewal of any insurance policy; (b) claims relating to the structure and subscription nature of the Lloyd’s market and the Society of Lloyd’s and its Franchise Performance Directorate and any successor, and the Lloyd’s Market Association and its predecessors, including but not limited to Federal and State RICO, civil conspiracy, unjust enrichment, anti-trust, fraud, unfair business practices, and consumer protection claims; (c) claims relating to anti-competitive conduct in the Lloyd’s market; and (d) the conduct and settlement of the Action (the “Released Claims”). Notwithstanding the foregoing, Plaintiffs and Settlement Class will not release by reason of this Settlement (defined below) claims for coverage under insurance policies issued to the Plaintiffs and the Settlement Class by the Syndicate Defendants or their predecessors or successors. Each of the Releasing Plaintiffs shall be deemed to have, and by operation of the Judgment shall have, fully, finally, and forever released, relinquished, and discharged each Released Defendant, including Settling Defendants’ Counsel, from all Claims (including Unknown Claims) arising out of, relating to, or in connection with the Released Claims or the Action. Releasing Plaintiffs, by virtue of the Notices, have been informed of Section 1542 of the California Civil Code and expressly waive and relinquish any rights or benefits available to them under this statute and any and all similar provisions, rights, and benefits conferred by any law of any state or territory of the United States or principle of common law that is similar, comparable, or equivalent to Section 1542 of the California Civil Code.
The Release as to the Plaintiffs, the Class, and their Counsel provides:
The Releasing Defendants shall release any claims they may have against the Releasing Plaintiffs related to the initiation, prosecution, conduct, and settlement of the Action, provided, however, that (a) “Released Claims” shall not include Releasing Plaintiffs’ Claims or Unknown Claims for, or Released Defendants’ defenses to, coverage under Contracts of Insurance issued to a Class Member (including either Plaintiff) or Releasing Plaintiff by a Released Defendant; and (b) Releasing Plaintiffs and Releasing Defendants will retain the right to enforce the Agreement and Exhibits, Preliminary and Final Approval Orders, Judgment, and other orders or judgments issued by the Court relating to Notice or the Settlement.