California, United States of America
The following excerpt is from Leung v. Verdugo Hills Hosp., B204908, No. BC343985 (Cal. App. 2011):
In Ash v. Mortensen (1944) 24 Cal.2d 654 (Ash), the court acknowledged the release rule, but refused to apply it to successive tortfeasors who produced separate, though related, injuries. The court held that the plaintiff's release of the negligent driver in a car accident in which the plaintiff was injured did not bar her
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