Free Complaint - District Court of Delaware - Delaware

FEB-22-2g[j§a$&1]Q55qv§(pp513-|\/IPT Document 17-4 Ftfiiiilhd. 07/21/2005 Page 1 of 2 P. U2
ASSIGNMEQI OF RIGHTS
I, Maly Yan, acknowledge Brat on January 20, 2005, Judge Sandra Moss found me I l
liable for damages in the action of Thou et gl. v. Yan Docket No. 030601508, in the total
amount of $10,228,46/.00 Dollars as a result of my actions surrounding an accident that
occurred on June 18, 2001.
· It is understood and agreed that Maly Yan hereby assigns to Yan Thou,
Individually, and as Administrator ofthe Estates of Ouem Man and Navy Yan, Chan
Thou, Thula Son and Chieu Thi Huyrh, her full rights, interest in, entitlement and claims
against the St. Patil Company a/lc/a St. Paul Travelers, and Pack and Process, Inc.,
including, without limitation, the right to file and pursue claims against St. Paul and Pack
2 and Process for indemnification, right to insurance coverage, declaratory judgment,
contribution, had faith and/or other remedies that Maly Yan otherwise may have or may
lj obtain arising out ot] among other things, St. Paul and Pack and Process’ obligations to
l- Maly Yan under its insurance agreements and/or policies of insurance issued by St. Paul
• 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
or agreements, directly or indirectly, connected with this assignment that are not
incorporated herein. This agreement shall be binding upon and inure to the successors,
assigns, heirs, executors, administrators, and legal representatives of the respective parties

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FEB_22_§05a?§E1 5tév $513 ocument 17 4 F5 $@07 21 2005 age 2 o 2 P. O3
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hereto.
THE UNDERSIGNED HEREBY DECLARES that the terms of this assignment have
been completely read; and that I have discussed the terms of this assignment with legal A
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 of the injuries and damages above—mentioned.
IN VVITNESS WHEREOF, I have hereunto set my h.and and seal this ’ Z 2 {JS"
/
day of , 2005.
MALY YANE l
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Social Security Number
Sworn to and subscribed .
. . ’Q»..,, , 2005.
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