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HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE AND THAT, IF
KNOWN BY HIM OR HER, WOULD HAVE MATERIALLY AFFECTED HIS OR HER
SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY.
Releasor expressly waives and relinquishes any right or benefit that Releasor has
or may have under Section 1542 of the California Civil Code and under any other statute
or legal principle with similar effect. In connection with such waiver and relinquishment,
Releasor acknowledges that she is aware that, after executing this General Release,
Releasor or Releasor's attorneys or agents may discover released Claims or facts in
addition to, or different from, those which they now know or believe to exist with respect
to the subject matter of this General Release, but that it is Releasor's intent hereby to fully,
finally and forever settle and release all of the Claims, whether known or unknown,
suspected or unsuspected, which now exist, may exist, or heretofore may have existed.
In furtherance of this intent, this General Release shall be, and remain in effect as, a full
and complete release of the Claims notwithstanding the discovery or existence of any
such additional or different Claims or facts.
The Administrator of the EVCP has retained Garretson Resolution Group, Inc.
d/b/a Epiq Mass Tort ("Epiq") to verify and resolve any lien or reimbursement claim
that may be owed to Medicare Part A and/or Part B ("Medicare") and/or Medicaid with
respect to compensation awarded to any participating claimant under the EVCP. If either
entity asserts a lien or reimbursement claim, Epiq is hereby authorized to act on behalf of
the EVCP to verify and resolve such lien or reimbursement claim. In the Claim Form,
Releasor authorized the Administrator to use and/or disclose information as to Releasor
for the resolution of Medicare and/or Medicaid liens. This includes providing to Epiq
certain information as to Releasor, including: (1) first name, last name and middle initial,
(2) Social Security number; (3) date of birth, (4) gender and (5) basic information
regarding the nature of Releasor's Claims, and authorizing the Administrator and Epiq
to use, exchange and report this information to Medicare and Medicaid, as may be
necessary, for purposes of verifying and resolving Medicare and/or Medicaid liens
and/or reimbursement claims and ensuring compliance with the Medicare Secondary
Payer Act, 42 U.S.C. § 1395(y)(b), and its accompanying regulations. In the event that
Epiq resolves the asserted claim or lien, the Epstein Estate will pay the negotiated amount
in addition to any Compensation Offer determined by the Administrator.
Releasor represents and acknowledges that she is voluntarily and freely granting
this General Release in exchange for payment of the Compensation Offer, and that she is
legally competent to execute and deliver this General Release. Releasor further
represents that she is represented by legal counsel and has received legal advice prior to
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