Engineered Abrasives, Inc. v. American Machine Products & Service, Inc.

Dist. Ct. did not err in finding that language in release from $75,000 settlement of subsequent lawsuit between parties also covered $714,814 default judgment entered against defendant in instant lawsuit so as to require dismissal of instant lawsuit. Relevant language of release provided that plaintiff released defendant “from any and all rights, claims…and/or causes of action…whether known or unknown…arising or occurring prior to and including date of the Agreement.” Moreover, although plaintiff contended that release was never intended to cover prior default judgment, Dist. Ct. could properly ignore plaintiff’s proffered extrinsic evidence to support its position, where language in release unambiguously released both default judgment in instant case and judgment in subsequent lawsuit. Fact that default judgment was not specifically mentioned in release did not require different result.