to get it because I saw it as an opportunity now to break through the logjam from the

          settlement standpoint.”

¶ 62          Pearson testified that at the mediation in November 2003, he, Bob Edwards, Ruth Kopec,

          and Brent Graber were present on behalf of Zurich and Foradas, Montgomery, and Massey

          were present on behalf of Motorola. Pearson testified that he “had an assurance going into

          that mediation that Motorola would accept the same terms—terms, language of the

       since several of the plaintiffs in the

          Valley litigation had alleged exposure to toxic chemicals “in their homes in their drinking

          water and showering in it in their homes.” Pearson further testified that no one told him that

          that the release was intended to release only outdoor claims or that the carveouts for asbestos

          and cell phone claims were not necessary but were only added as a precaution. Pearson was

          also unaware of the content of the negotiations between Associated and Motorola that

