Common Contracts

S ETTLEMENT AGREEMENT AND RELEASE

Settlement Agreement • December 16th, 2019 • Virgin Islands

• Contract Type
  Settlement Agreement
• Filed
  December 16th, 2019
• Jurisdiction
  Virgin Islands

This Settlement Agreement and Release (this “Agreement”) is hereby made by and between the Hovensa Liquidating Trust by and through Jay Borow, as Liquidating Trustee (the “Trustee”), on the one hand, and (a) Liberty Mutual Insurance Company (“Liberty Mutual”) and Liberty Surplus Insurance Corporation (“Liberty Surplus” and, together with Liberty Mutual, “Liberty”); (b) National Union Fire Insurance Company of Pittsburgh, Pa., Illinois National Insurance Company, and Lexington Insurance Company (collectively the “AIG Member Companies”); and (c) ACE American Insurance Company, Indemnity Insurance Company of North America, and Westchester Surplus Lines Insurance Company (collectively the “Chubb Insurers”), on the other hand. Liberty, the AIG Member Companies and the Chubb Insurers are referred to herein collectively as the “Settling Insurers.” The Trustee and each of the Settling Insurers may be referred to herein individually as a “Party,” or together as the “Parties.”