Free Amended Complaint - District Court of Delaware - Delaware

Case 1:05-cv-00513-MPT Document 18-4 Filed 07/21/2005 Page 1 of 2
ASSIGNMENT OF RIGHTS
I, Maly Yan, acknowledge that on January 20, 2005, Judge Sandra Moss found me
liable for damages in the action of Thou et al. v. Yan Docket No. 030601508, in the total
amount of $l0,228,467.00 Dollars as a result of my actions surrounding an accident that
occurred on June 18, 200l.
It is understood and agreed that Maly Yan hereby assigns to Yan Thou,
Individually, and as Administrator of the Estates of Ouern Man and Navy Yan, Chan
Thou, Thula Son and Chieu Thi Huynh, her full rights, interest in, entitlement and claims
against the St. Paul Company a/k/a St. Paul Travelers, and Pack and Process, Inc.,
including, without limitation, the right to tile and pursue claims against St. Paul and Pack
lg and Process for indemnification, right to insurance coverage, declaratory judgment,
contribution, bad faith and/or other remedies that Maly Yan otherwise may have or may
i obtain arising out of, among other things, St. Paul and Pack and Process’ obligations to
I Maly Yan under its insurance agreements and/or policies of insurance issued by St. Paul
I and/or any other insurance carrier, and/or St. Paul and Pack and Process’ conduct during
the negotiations in this legal action, Maly Yan agrees to cooperate with the investigation
and pursuit of those claims. ‘
It is further understood and agreed that there are no written or oral understandings
i or agreements, directly or indirectly, connected with this assignment that are not
i incorporated herein. This agreement shall be binding upon and inure to the successors,
assigns, heirs, executors, administrators, and legal representatives of the respective parties
if

Case 1:05-cv-00513-MPT Document 18-4 Filed 07/21/2005 Page 2 of 2
hereto.
THE UNDERSIGNED HEREBY DECLARES that the terms of this assigmnent have
been completely read; and that I have discussed the terms of this assignment with legal
counsel of my choice; and that said terms are fully understood and voluntarily accepted for
the purpose of making a full and final assignment of rights of any and all claims on
account ofthe injuries and damages above-mentioned.
IN WITNESS WHEREOF, I have hereunto set my hand and seal this ‘ 2 2 OSA
/
day of k , 2005.
MALY YAN E i
jilj ȤS' {{832
I, Social Security Number
i Sworn to and subscribed
· this *],2,,,,.9. day of
J , 2005.
I N a . Pu i .

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