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FULL AND FINAL RELEASE AND INDEMNITY AGREEMENT

KNOW ALL PERSONS BY THESE PRESENTS that the undersigned, ANNE

FUHRMANN, for and in consideration of a payment in the sole sum of

TWELVE THOUSAND, FIVE HUNDRED ($12,500.00) DOLLARS, in hand

paid by JONATHON THROCKMORTON AND SAFE AUTO INSURANCE

COMPANY, the receipt and sufficiency of which is hereby acknowledged, on

behalf of herself and her heirs, executors, administrators, successors, agents

and assigns, does hereby fully and forever release, acquit and discharge

JONATHON THROCKMORTON AND SAFE AUTO INSURANCE COMPANY, their

heirs, executors, administrators, agents, successors and assigns, from any and

all claims, demands, rights, actions, causes of action and/or suits, at law or in

equity, and every kind and nature whatsoever, particularly on account of or in

any way arising from injuries, damages, disabilities and/or losses to both

person and property, which have resulted or may in the future develop as a

result of any acts or omissions relating to the auto accident that occurred at or

near the intersection of State Route 348 and Owensville Road in the City of Rush,

Scioto County, Ohio on or about October 9, 2006, including any and all claims

asserted against Jonathon Throckmorton Michael Johnson in Case No. 09-CI-1567

on the docket of the Scioto County Court of Common Pleas styled, “Anne

Fuhrmann vs. Jonathan Throckmorton, et al.”

IT IS UNDERSTOOD AND AGREED that the undersigned specifically and

expressly intends to fully remise, release, acquit and forever discharge any and all

past, present and future claims, demands, rights, liens, actions, causes of action,
suits, damages, judgments, liabilities, controversies, obligations, compensation,

loss of services, debts, medical or hospital expenses, lost wages, future

impairment, deductibles, commissions, interest, expenses, costs and fees, of

whatsoever kind and nature, whether based in tort, equity, contract, statute,

regulation or otherwise, and whether same could have been brought before any

court, administrative board, body, agency or any other forum, and all

consequential damages on account of or in any way arising out of injuries,

damages, disabilities and/or losses to person or property, known or unknown,

vested and contingent, suspected or not, and any other claims that the

undersigned asserted or may have asserted in the aforesaid civil action, or which

resulted or may in the future develop as a result of any acts or omissions related

to the aforesaid accident, together with any claims and suits in connection with the

defense, adjustment, negotiation and/or settlement of the same by all agents,

servants, representatives, employees, adjusters and attorneys of Michael Johnson

and Safe Auto Insurance Company.

IT IS FURTHER UNDERSTOOD AND AGREED that in making this

instrument and the settlement embodied herein, the undersigned has taken into

consideration not only ascertained injuries, disabilities, damages and losses, but

also any not yet ascertained injuries, disabilities, damages and losses, and the

possibility that any such sustained may be permanent and progressive and

recovery therefrom uncertain and indefinite, so that consequences not now

anticipated may hereafter result; and, that the undersigned has relied wholly

upon her own judgment, belief and knowledge and has not to any extent

whatsoever been influenced or induced by any representations or statements


as to the nature, extent or duration of any injuries, disabilities, damages and

losses, or the nature and extent of legal liability or financial responsibility of

any person and entity and/or any other manners, made by persons, firms or

entities hereby released, or by any person, entity, agent, or attorney

representing them, or by any physician, surgeon, medical provider,

representative or agent by them employed.

IT IS FURTHER UNDERSTOOD AND AGREED that the undersigned shall

be fully and solely responsible for the negotiation, compromise and satisfaction

of all outstanding liens or claims of any third-parties, non-parties, persons and

entities, including, but not limited to the claim for medical payments of State

Farm Mutual Automobile Insurance Company, and does hereby agree to save,

defend, indemnity and hold harmless Jonathan Throckmorton and Safe Auto

Insurance Company, from and against any and all further such liens, claims,

demands, losses, actions, causes of action, damages, liabilities, obligations,

judgments, costs, expenses and attorney’s fees, known and unknown, made

against or sustained by the undersigned, or any of her successors and assigns,

including all amount which have or may at any time be asserted, claimed,

sought or recovered by any person, insurer, governmental agency or other

entity subrogated to the right of the undersigned by or against any hospital,

physician or other medical provider of whatsoever kind or nature, which

provided any medical, hospital or other services as a result of the aforesaid

accident. Said indemnification shall include all attorney fees, costs and other

expenses incurred in prosecuting any such claims or demands.

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IT IS FURTHER UNDERSTOOD AND AGREED that, regardless of the passage

of time between the date of settlement or execution of this instrument and the

date that payment is actually made or received, Jonathan Throckmorton and Safe

Auto Insurance Company shall never be obligated to pay any interest or additional

sums, and that neither Ohio R.C. § 1343.03 nor the holding of Hartmann v. Duffey

(2002), 95 Ohio St. 3d 456, which may allow interest to accrue on the amount of

settlement, shall be applicable.

IT IS FURTHER UNDERSTOOD AND AGREED that this instrument and the

settlement embodied herein constitute the compromise of doubtful and disputed

claims, that the consideration reflected herein is made solely to terminate further

litigation and controversy as to all claims heretofore or hereafter asserted, and

shall in no way be construed as or deemed to be an admission of liability by or on

behalf of Jonathan Throckmorton and Safe Auto Insurance Company, or any of

their employees, agents, representatives, heirs, successors and assigns, all by

whom liability is expressly denied.

IT IS FURTHER UNDERSTOOD AND AGREED that this instrument sets forth

the full, final and complete agreement and understanding between the parties;

that all prior and contemporaneous representations or statements are merged

herein; that no promise, inducement or agreement not herein expressed has been

made; and, that the terms and conditions herein are contractual and not a mere

recital.

THE UNDERSIGNED HEREBY WARRANT AND AGREE to execute any

documentation necessary to dismiss with prejudice all claims and suits filed by or

on behalf of the undersigned as a result of the aforesaid accident; that she has

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been fully compensated for all damages and the consideration reflected herein

constitutes payment in full satisfaction of any and all claims; and, that she shall

keep all terms and conditions of this release and the settlement embodied herein

confidential.

THE UNDERSIGNED HEREBY CERTIFIES THAT SHE HAS CAREFULLY READ


THIS INSTRUMENT, KNOWS AND FULLY UNDERSTANDS ALL OF ITS
CONTENTS, IS SIGNING BELOW OF HER OWN FREE WILL AND VOLUNTARY
ACT, AND HAS BEEN FULLY AND ADEQUATELY REPRESENTED BY LEGAL
COUNSEL, HON. RICHARD W. CAMPBELL, ESQ., IN ALL STAGES OF THE
NEGOTIATION, SETTLEMENT AND RELEASE OF THE WITHIN CLAIMS.

___________________ ___________________________________
DATE ANNE FUHRMANN

STATE OF OHIO )
SS:
COUNTY OF SCIOTO )

Subscribed, sworn to and acknowledged before me, a Notary Public, by


Anne Fuhrmann, on this ____ day of September, 2010.

_________________________________
NOTARY PUBLIC

My commission expires: __________