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COUNTY OF BRONX : PART I-23 ---------------------------------------------------------------------x PIERRE ALEXANDRE and LOVELY ALEXANDRE -against- MIGUEL SEGURA ---------------------------------------------------------------------x INDEX No. 28955/2001 IT IS HEREBY STIPULATED AND AGREED by and between the below-named attorney(s) as follows: The parties agree to settle the above matter as follows: 1. If there is a finding of liability against defendant in the amount of 20% or greater, defendant and/or his carrier shall pay $1,000,000.00 (one million dollars) to plaintiff. 2. If there is a finding of 100% in favor of defendant (a defendant’s verdict), defendant shall pay $300,000.00 (three hundred thousand dollars) plaintiff. 3. If there is a finding for plaintiff, but defendant is assessed less than 20%, defendant and/or his carrier shall pay that prorated share of $1,000,000.00 (one million dollars): for example 15% equals $750,000.00 (seven hundred fifty thousand dollars), 10% equals $500,000.00 (five hundred thousand dollars), to a minimum of $300,000.00 (three hundred thousand dollars). 4. If a defendant is assessed 6% liability or less, defendant shall pay $300,000.00 (three hundred thousand dollars) to plaintiff 5. The workers compensation carrier approved this settlement. 6. There shall be no damage trial, no appeals, and no post-trial motions and no cost or interest to either side. So Ordered. |
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