“Affiliate” means a person in a dependent or subordinate relationship with another, not just anyone with some sort of connection to the other; so a settlement agreement’s release did not extend to the lessor of released defendants and plaintiff’s suit against that entity could proceed. A release of a used car dealer and a tow truck operator and their “affiliates” and persons “affiliated” with them did not release claims against a different, former used car dealer that had leased the dealership property to the defendant used car dealer and had left several cars with that dealer to sell on consignment. “Affiliate” means a person in a dependent or subordinate relationship with another, not just anyone with some sort of connection to the other. Here, the former used car dealer didn’t have any subordinate or dependent relationship to the released car dealer and so did not come within the scope of the release.
California Court of Appeal, Third District (Nicholson, J.); March 24, 2017; 2017 WL 1101421