Motion for Writ in Altagracia B Pierre-Outerbridge As Administrator Of the Estate of Lindrick Arthur Outerbridge a/k/a Lindrick Outerbridge, deceased v. Camnine Outerbridge, Ruben Outerbridge, Reese Outerbridge, Jennie Davenport a/k/a Jennie Outerbridge, Keith Outerbridge, Elijah Davenport, John Doe, Jane Doe| Trellis.Law

On October 11, 2021 a Order to Show Cause was filed involving a dispute between Altagracia B Pierre-Outerbridge As Administrator Of The Estate Of Lindrick Arthur Outerbridge A K A Lindrick Outerbridge, Deceased, and Camnine Outerbridge, Elijah Davenport, Jane Doe, Jennie Davenport A K A Jennie Outerbridge, John Doe, Keith Outerbridge, Reese Outerbridge, Ruben Outerbridge, for Commercial - Other (Ejectment, U&O, Waste) in the District Court of Nassau County.

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
------------------------------------------------------------------------
ALTAGRACIA B. PIERRE-OUTERBRIDGE, as
administrator of the Estate of LINDRICK ARTHUR
OUTERBRIDGE (a.k.a LINDRICK OUTERBRIDGE), Index No.: 612930/2021
deceased,
AFFIRMATION OF
Plaintiff, RACHEL M. LUST
vs.

CAMNINE OUTERBRIDGE, RUBEN
OUTERBRIDGE, REESE OUTERBRIDGE, JENNIE
DAVENPORT (a.k.a. JENNIE OUTERBRIDGE),
KEITH OUTERBRIDGE, ELIJAH DAVENPORT,
“John Doe” and “Jane Doe,”
Defendants.
------------------------------------------------------------------------

Rachel M. Lust, an attorney duly admitted to practice law before the courts of the State of

New York, affirms, pursuant to Rule 2106 CPLR, under penalties of perjury under the laws of New

York, which may include a fine or imprisonment, that the following facts are true, and I understand

that this document may be filed in an action or proceeding in a court of law:

1. I am an associate at Dorf Nelson & Zauderer LL//P (“DNZ”), attorneys for Defendant

JENNIE DAVENPORT a/k/a JENNIE OUTERBRIDGE (“Defendant”) herein, and as such

I am familiar with the facts and circumstances and prior pleadings and proceedings

heretofore had herein.

2. I submit this Affirmation in support of Defendant’s motion to withdraw as counsel and to

stay this action pending the determination of this application and for a period of ninety (90)

days thereafter for Defendant to obtain alternative counsel.

3. Initially, I remind the Court that this Court does not have jurisdiction over Defendant as

Defendant, a resident of the State of California with no ties to New York, has a pending

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motion in this Court to dismiss Plaintiff’s complaint for lack of personal jurisdiction over

Defendant pursuant to CPLR § 3211(a)(8).

4. A true and correct copy of the Settlement Agreement between Altagracia B. Pierre-

Outerbridge, as administrator of the Estate of Lindrick Arthur Outerbridge and as Guardian

of the Property of the Property of Andrick A. Outerbridge, Jennie Davenport a/k/a Jennie

Outerbridge executed on or about September 1, 2022 is annexed hereto as Exhibit A.

5. Plaintiff Altagracia B. Pierre-Outerbridge, as administrator of the Estate of Lindrick Arthur

Outerbridge a/k/a Lindrick Outerbridge (“Plaintiff”) has refused on countless occasions to

discontinue the above referenced action in direct contravention of the Settlement

Agreement.

6. Specifically, with regard to this action, the Settlement Agreement states:

16. Dismissal of All Actions Against Davenport and all Davenport Released
Parties: Outerbridge swears and affirms under penalty of perjury that she is not
presently aware of any other actions brought by her or anyone within her control
except for those listed below. Based on this material representation, Outerbridge
and Davenport enter into the herein Agreement. The actions commenced by
Outerbridge, APO Administrator and/or APO Guardian shall be discontinued as
follows:

c. The Ejectment Action: The Ejectment Action shall be discontinued with
prejudice and all motions shall be withdrawn upon the filing of a Stipulation
of Discontinuance. Stipulation shall simply say that matter is discontinued.

(emphasis supplied)

7. Because of Plaintiff’s unreasonable refusal to discontinue the action, in direct contradiction

to the Settlement Agreement, DNZ has continued to represent Defendant and has attempted

to appease Plaintiff in her attempts to obtain approval from the Surrogates Court, which

approval was never contemplated in the Settlement Agreement.

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8. Specifically, Defendant has prepared stipulation of discontinuances for Plaintiff to sign and

made countless calls to try and persuade Plaintiff to execute the stipulation to discontinue

this action.

9. However, as a result of the Surrogates Court order, DNZ has determined that enough is

enough.

10. We have once again attempted to get Plaintiff to sign a stipulation of discontinuance;

however, again, she has refused. It is curious because, not only is it mandated int eh

Settlement Agreement but Plaintiff will not be able to continue her efforts without

cooperation from Defendant who will be unrepresented and not be subject to the

jurisdiction New York Courts. One would think that Plaintiff would have been more

cooperative.

11. DNZ has been working without payment free since January, 2022.

12. To date, the last payment that DNZ has received as counsel was on January 12, 2022.

Additionally, DNZ has incurred a large balance of $9,993.59 due to Plaintiff’s refusal to

discontinue these two supreme court actions.

13. Our decision to be relieved as attorneys is consistent with all ethical considerations,

pursuant to which all attorneys must comport themselves.

14. No prior application has been made to this or any other court for the relief requested herein;

however, similar order to show cause are being filed simultaneously in the matter of

Altagracia B. Pierre-Outerbridge, as administrator of the Estate of Lindrick Arthur

Outerbridge a/l/a Lindrick Outerbridge v. Jennie Davenport a/k/a Jennie Outerbridge, et

al., Supreme Court, Nassau County Index Number 612957/2021 and the matter of In the

Matter of the Petition of Altagracia B. Pierre-Outerbridge, in her Individual Capacity, as

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Guardian of the Property of Andrick A. Outerbridge, and as the Administrator of the Estate

of Lindrick Outerbridge, Surrogates Cour, Nassau County Index Numbers 2021-2490/A

and 2021-2490/D.

WHEREFORE, Defendant respectfully prays for an Order granting its motion to be

relieved as counsel and to dismiss this action against Defendant in its entirety and for such other

and further relief as this court deems just and necessary.

Dated: Rye, New York
April 15, 2024

_________________________
Rachel M. Lust, Esq.

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SETTLEMENT AGREEMENT

THIS SETTLEMENT AGREEMENT (“Agreement”), made and effective this --- 1
day of September, 2022, by and between Altagracia B. Pierre-Outerbridge, in her individual
capacity (“Outerbridge”), Altagracia B. Pierre-Outerbridge, as Administrator of the Estate of
Lindrick Arthur Outerbridge (“APO Administrator”), Altagracia B. Pierre-Outerbridge, as
Guardian of the Property of Andrick A. Outerbridge (“APO Guardian”), and Jennie Davenport
a/k/a Jennie Outerbridge (“Davenport”) (each party hereto a “Party” and collectively the
“Parties”).

WHEREAS, Lindrick Arthur Outerbridge (a.k.a. Lindrick Outerbridge) (the “Decedent”)
passed away on April 17, 2021 (the “Date of Death”), in New York;

WHEREAS, Outerbridge is the Decedent’s former spouse, the Administrator of the Estate
of Lindrick Arthur Outerbridge (the “Estate”), and the Guardian of the Property of Andrick A.
Outerbridge;

WHEREAS, Andrick A. Outerbridge is the only child and sole heir of the Decedent (the
“Andrick” or “Sole Heir”);

WHEREAS, on or about January 5, 2021, Outerbridge filed a petition in Surrogate’s Court
of the State of New York, County of New York, seeking Letters of Guardianship 17 with
Limitations Property Only for Andrick A. Outerbridge, File No. 2021-2327;

WHEREAS, there is a Domestic Relations Order (“DRO”) dated December 16, 2021,
which is based on a Stipulation dated March 4, 2019, entered into between Outerbridge and the
Decedent in their dissolution of marriage proceeding in Nassau County Supreme Court, Index No.
202556/2017 (the “Stipulation”);

WHEREAS, pursuant to the DRO, 24% of the Decedent’s Qualified Pension Plan pre-
retirement death benefit at the Teachers’ Retirement System of the City of New York (“TRS”) is
to be disbursed to Outerbridge, in the amount of approximately $87,401.00;

WHEREAS, in or around June, 2021, Outerbridge filed a Petition for Letters of
Administration in Surrogate’s Court of the State of New York, County of Nassau, File No. 2021-
2490, seeking Letters of Administration with respect to the Estate of the Decedent (the
“Administration Proceeding”);
1

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WHEREAS, Letters of Administration were issued to Outerbridge in the Administration
Proceeding on August 25, 2021 and have thereafter been renewed and amended;

WHEREAS, on or about September 9, 2021, Outerbridge commenced an action in
Supreme Court, State of New York, County of New York, Index No. 158320/2021, entitled
Altagracia B. Pierre-Outerbridge v. Natalie Adams, seeking an injunction and setting forth claims
of libel per se, intentional infliction of emotional distress, harassment and extortion (the “Libel
Action”);

WHEREAS, on or about October 10, 2021, Outerbridge, APO Administrator and APO
Guardian filed a petition in Surrogate’s Court of the State of New York, County of Nassau, File
No. 2021-2490/A, entitled In the Matter of the Amended Petition of Altagracia B. Pierre-
Outerbridge, in her Individual Capacity, as Guardian of the Property of Andrick A. Outerbridge,
and as the administrator of the Estate of Lindrick Arthur Outerbridge (a.k.a. Lindrick
Outerbridge) deceased (“Petitioner”), For a Decree Directing Teachers’ Retirement System of
the City of New York (“TRS”) to Turnover Property Withheld, seeking turnover of Decedent’s
Pension with TRS, to which Davenport has made a claim (the “TRS Turnover Action”);

WHEREAS, on or about October 10, 2021, Outerbridge, APO Administrator and APO
Guardian filed a petition in Surrogate’s Court of the State of New York, County of Nassau, File
No. 2021-2490/D, entitled In the Matter of the Amended Petition of Altagracia B. Pierre-
Outerbridge, in her Individual Capacity, as Guardian of the Property of Andrick A. Outerbridge,
and as the administrator of the Estate of Lindrick Arthur Outerbridge (a.k.a. Lindrick
Outerbridge) deceased (“Petitioner”), For a Decree Directing The Vanguard Group, Inc. and
United Federation of Teachers to Turnover Property Withheld, seeking a turnover of funds
belonging to the Decedent with Vanguard and UFT Welfare Fund, to which Davenport has made
a claim (the “Vanguard/UFT Turnover Action”);

WHEREAS, on or about October 11, 2021, APO Administrator commenced an action in
Supreme Court of the State of New York, County of Nassau, Index No. 612930/2021, entitled
Altagracia B. Pierre-Outerbridge, as Administrator of the Estate of Lindrick Arthur Outerbridge
(a.k.a. Lindrick Outerbridge), deceased, against Camnine Outerbridge, Ruben Outerbridge, Reese
Outerbridge, Jennie Davenport (a.k.a. Jennie Outerbridge), Keith Outerbridge, Elijah Davenport,
John Doe and Jane Doe, for ejectment and use and occupancy with respect to property belonging

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to the Estate of Lindrick Arthur Outerbridge located at 49 Gold Street, Valley Stream, NY
(“Property”) (the “Ejectment Action”);

WHEREAS, on or about October 12, 2021, APO Administrator commenced an action in
the Supreme Court of the State of New York, County of New York, Index No. 612957/2021,
entitled Altagracia B. Pierre-Outerbridge, as Administrator of the Estate of Lindrick Arthur
Outerbridge (a.k.a. Lindrick Outerbridge), deceased, against Jennie Davenport (a.k.a Jennie
Outerbridge) and Camnine Outerbridge, for conversion and theft of property belonging to the
Estate of Lindrick Arthur Outerbridge (the “Conversion Action”);

WHEREAS, on or about February 15, 2022, APO Guardian commenced an action in the
Supreme Court of the State of New York, County of New York, Index No. 151413/2022 entitled
Altagracia B. Pierre-Outerbridge, as legal guardian of and on behalf of A.O. against Jennie
Davenport (a.k.a. Jennie Outerbridge) and Camnine Outerbridge, for unlawful sepulcher,
intentional inflection of emotional distress and seeking a turnover of the ashes of the Decedent (the
“Sepulcher Action”);

WHEREAS, Davenport is the sister of the Decedent;

WHEREAS, on March 22, 2022, Davenport filed a petition under Chapter 13 of the
Bankruptcy Code in the United States Bankruptcy Court for the Central District of California,
Riverside Division, Case No. 22-bk-11041-WJ (the “Bankruptcy Action”);

WHEREAS, on April 5, 2022, Davenport filed sworn Schedules in the Bankruptcy Action;

WHEREAS, in her Schedule A/B, Davenport identified an alleged interest in an “Inherited
Pension” which she described as “Teacher’s Retirement System of the City of New York” which
she claimed that the Decedent left to Davenport but was frozen due to claims made by Outerbridge
on behalf of Decedent’s son (the “TRS Account”);

WHEREAS, Davenport valued her interest in the TRS Account at $449,247.44;

WHEREAS, Outerbridge contended that no portion of the TRS Account is property of the
bankruptcy estate, having filed the TRS Turnover Action for, inter alia, a determination that
Davenport is not the proper beneficiary of the TRS Account and is not entitled to any portion of
the funds in the TRS Account;

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WHEREAS, on or about June 8, 2022, Outerbridge, as Administrator of the Estate of the
Decedent, filed a Motion for Relief from the Automatic Stay (the “MFRS”) in the Bankruptcy
Action with respect to the TRS Turnover Action, the Vanguard/UFT Turnover Action, the
Ejectment Action, the Sepulcher Action, and the Conversion Action;

WHEREAS, Davenport swears and affirms under penalty of perjury that she is presently
not aware of any other accounts except for those listed in the Conversion Action. Based on this
material representation, Outerbridge and Davenport enter into the herein Agreement.

WHEREAS, after hearing argument on the MFRS on June 29, 2022, the court in the
Bankruptcy Action continued the hearing on the MFRS and ordered supplemental briefing;

WHEREAS, the next hearing date with respect to the MFRS is August 10, 2022;

WHEREAS, the confirmation hearing in the Bankruptcy Action is scheduled for
September 26, 2022;

NOW, THEREFORE, in consideration of the execution of the Agreement and the mutual
promises, undertaking, and commitments contained herein and other good and valuable
consideration the Parties to the Agreement have received, the receipt and sufficiency of which are
hereby acknowledged, the Parties agree as follows:

1. Pension Funds: As of today, the pension funds equal approximately $449,247.44 (four
hundred forty nine thousand two hundred forty seven dollars and forty four cents)
comprising approximately $364,171.79 (three hundred sixty four thousand one
hundred seventy one thousand dollars and seventy nine cents) in QPP preretirement
death benefits, including the portion of these death benefits awarded by the DRO, and
a TDA of approximately $85,075.65 (eighty five thousand seventy five dollars and
sixty five cents) (the “Pension Funds”).
2. Disbursement Pursuant to DRO: Pursuant to the DRO Order, twenty-four percent
(24%) of the QPP Funds shall be distributed to Outerbridge. Outerbridge shall make
application to TRS for this distribution of funds from the QPP Funds within thirty (30)
days of the date of this TRS Agreement.

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3. Disbursement to Davenport: On or after November 1, 2022, Davenport is authorized
to make application to TRS for a distribution of nineteen percent (19%) of the QPP
Funds.
4. Disbursement to the Estate of Lindrick Arthur Outerbridge: On or after December
1, 2022, APO Administrator is authorized to make application to TRS for a distribution
of the remaining fifty-seven percent (57%) of the QPP Funds and for a distribution of
one-hundred percent (100%) of the TDA Funds.
5. TRS Death Benefits: The parties recognize that the amount of the Pension Funds may
fluctuate, as the amounts are estimates. For this reason, the amounts are listed in
percentages.
6. Division and Payment of TRS Benefits
a. Qualified Pension Plan benefits
The Decedent’s Qualified Pension Plan pre-retirement death benefit beneficiaries,
including the designation in favor of Outerbridge in accordance with the DRO on
file, shall be designated as follows:
Altagracia B. Pierre-Outerbridge: 24%, in accordance with the DRO on file.
Jennie Davenport: 19%
The Estate of Lindrick Arthur Outerbridge: 57%
b. Tax Deferred Annuity Benefits
The Decedent’s Tax Deferred Annuity death benefit beneficiaries shall be
designated as follows:
The Estate of Lindrick Arthur Outerbridge: 100%
c. Before starting the claims process to issue payments to the beneficiaries other
than Outerbridge, TRS requires proof that the Temporary Restraining Order
dated October 7, 2021 issued by the Nassau County Surrogate Court in the case
In Re Pierre-Outerbridge (File No. 2021-2490) (the “TRO”) has been lifted.
d. TRS’ responsibility in connection with this settlement is limited to
implementing the beneficiary designation specified in this Section 6 of the TRS
Settlement and processing claims for these benefits submitted by the designated
beneficiaries in the normal course of business. In accordance with TRS’ regular
processing timeframe, once the above prerequisites are satisfied and a

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beneficiary submits a valid claim and any required supporting documentation,
TRS may take several months to review the claim and issue payment.
7. Total Settlement Funds: The Total Settlement Funds are as follows: The United
Federation of Teachers Welfare Fund account contains $6,000.00 (six thousand dollars) (the "UFT
Welfare Fund Account"). The Vanguard Group, Inc. account contains $14,378.30 (fourteen
thousand three hundred seventy-eight dollars and thirty cents) (the "Vanguard Account").
Collectively, the Pension after QRDO, the UFT Account and the Vanguard Account total
approximately $382,224.50 (three hundred eighty-two thousand two hundred twenty-four
thousand dollars and fifty cents) (the "Total Settlement Funds").
8. Disbursement of Portion of Total Settlement Funds to Davenport: The
following shall be disbursed to Davenport:
a. the $6,000.00 (six thousand dollars) in the UFT Welfare Fund Account;
b. the $14,378.30 (fourteen thousand three hundred seventy-eight dollars and
thirty cents) in the Vanguard Account; and
c. 19% of the QPP Funds as set forth above.
d. Notwithstanding the actual value of each of the accounts listed in a. through c.,
~ ·~Qr, Davenport shall receive the total sum ofNinety Thousand Dollars ($90,000.00).
/'1:c,11''\\ In the event that the amount paid by TRS to Davenport is less than $90,000,
, \\ tIJI''-"'\:'~ ~ k Outerbridge will pay the difference to Davenport, such that the total amount
~~l\X'"-!Je,l ,~ received by Davenport equals $90,000, within 15 days of the payment By T RS
O ;J~ ~\ • ~~~to
\0 C,«'.-~-,-1-lf-~e-)U \
Davenport. In the event that the amount paid by TRS to Davenport exceeds
$90,000, Davenport will pay any amount in excess of $90,000 to Outerbridge
'o ~1,~-)
11\ {,
j ¥oo~ : ~~I I
within 15 days of rece i 11 of the final a ment. D,n ,ort sha 11 , rovide , roof
;;:unts received within 5 day, of the payment.reeeipt ef the paymeat

iv)~,Of \ Disbursement of Pension Funds After Settlement: Pension funds distributed to
the Estate in connection with this Settlement will be distributed to or rolled over
~lJJ .{)at, '\ into a qualified account for the benefit of Andrick. Outerbridge, in any of her
ft\ .. o.._'1,'v capacities, waives any right to payment of fees, costs, legal fees, etc. from the
~ Pension Funds.
Execution of Additional Documents. The Parties agree that they shall fully
cooperate with all due speed and diligence and provide, execute, etc. any and all
6

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documents necessary or requested for the disbursement of all funds as set forth

above within three (3) business days and take all additional steps which may be
necessary or convenient to consummate this Agreement and accomplish the
purposes thereof.
11. Ashes of the Decedent: Davenport agrees to surrender the Decedent’s Ashes as
defined below to Outerbridge for the benefit of Andrick within ten (10) days of the
execution of this Agreement. Outerbridge has been advised that such remaining
ashes are contained in a locket that Davenport purchased for Andrick (“Ashes”) and
its contents are the sole ashes that remain. The Ashes shall be sent to Outerbridge
at the following address where signature upon delivery will be required:
Outerbridge Law P.C. 250 Park Ave, 7th Floor, Suite 7020, New York, New York
10177.
12. Unauthorized Transaction: As of the date of execution of this Agreement, except
for previously refunded amounts, Outerbridge swears and affirms that she, in any
capacity, will not seek the refund or return of any funds previously disbursed to
Davenport. Based upon this representation, Davenport agrees that she shall not
interfere with any refunds of amounts refunded or returned by any financial
institution concerning any transactions deemed unauthorized by another party not
released in this Agreement, and with the exception of defending herself against any
such action that may be brought against her by someone other than a party named
in this Agreement. If any such funds are returned or refunded to Davenport,
Davenport shall return such funds to the Estate within three (3) business days via
bank check written to the Estate of Lindrick Arthur Outerbridge and shall deliver
such check to Outerbridge, as Administrator of the Estate.
13. Communication Limitation: Davenport agrees not to contact Outerbridge in any
capacity or Andrick until he reaches the age of eighteen (18) years old, or until a
court of competent jurisdiction enters an order allowing Davenport to contact
Andrick/altering this provision of the Agreement which Davenport reserves the
right to seek from such court of competent jurisdiction. Outerbridge in all capacities
reserves all defenses. Davenport shall not contact Outerbridge Law or any
endeavors involving Outerbridge. Davenport shall not induce any other individuals
to contact Outerbridge or Andrick until he reaches the age of eighteen (18) years
7

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old, or until a court of competent jurisdiction enters an order allowing Davenport
to contact Andrick/altering this provision of the Agreement which Davenport
reserves the right to seek from such court of competent jurisdiction. Outerbridge,
in any capacity, shall not contact Davenport or any of the other parties released in
this Agreement. As of the date of execution of this agreement, Outerbridge shall
not induce any other individuals within her control to contact Davenport or any of
the other parties released in this Agreement except to enforce the terms of this
Agreement.
14. Withdrawal of the MFRS: The Parties shall execute a stipulation to withdraw the
MFRS upon execution of this Agreement.
IS. Dismissal of Bankruptcy Action: Davenport shall voluntarily dismiss the
Bankruptcy Action within ten (10) days after the MFRS is withdrawn.
I6. Dismissal of All Actions Against Davenport and all Davenport Released
Parties: Outerbridge swears and affirms under penalty of perjury that she is not
presently aware of any other actions brought by her or anyone within her control
except for those listed below. Based on this material representation, Outerbridge
and Davenport enter into the herein Agreement. The actions commenced by
Outerbridge, APO Administrator and/or APO Guardian shall be discontinued as
follows:
a. The Libel Action: Upon execution of this Agreement, the Libel Action shall
be discontinued without prejudice, provided Defendant in that action executes
a stipulation to that effect. The permanent injunction obtained in that action
remains in full effect and Outerbridge shall be entitled to enforce the injunction
in the event of any breach thereof. The stipulation shall simply state that the
matter is discontinued wi+lt-without prejudice, but the permanent injunction
which shall remain in full force and effect.
b. The Sepulcher Action: The Sepulcher Action shall be discontinued with
prejudice upon receipt by Outerbridge of the Decedent's Ashes within ten (10)
days of the execution of this Agreement as set forth in Paragraph 11 above by
the filing of a Notice of Discontinuance. To the extent in Davenport's
possession, Davenport shall also provide, within ten ( 10) days of execution of

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this Agreement, a copy of the zoom funeral service/memorial service and a copy
of any notes by Decedent to Andrick.
c. The Ejectment Action: The Ejectment Action shall be discontinued with
prejudice and all motions shall be withdrawn upon the filing of a Stipulation of
Discontinuance. Stipulation shall simply say that matter is discontinued.
d. The Conversion Action: The Conversion Action shall be discontinued with
prejudice and all motions shall be withdrawn upon the filing of a Stipulation of
Discontinuance. Stipulation shall simply say that matter is discontinued.
e. The TRS Turnover Action: The Parties shall take any actions necessary to lift
the TRO and any other legal restraint preventing TRS from disbursing the
Decedent’s QPP and TDA death benefits in accordance with this Settlement.
The TRS Turnover Action shall then be discontinued with prejudice.
17. No Interference in Administration Proceeding. Davenport agrees that she
hereby waives all rights to participate in the Administration Proceeding. Davenport
agrees that she shall not interfere in any manner in the Administration Proceeding
or the administration of the Estate and shall not cause any other party to so interfere.
Davenport agrees that she shall not act or attempt to act as ultra vires administrator
of the Estate. Davenport agrees that she shall not purport to speak or act for the
Estate and shall not execute any documents or cash any checks or other funds
belonging to the Decedent or the Estate and agrees that she shall immediately turn
over any such funds to the Estate.
18. Release by Outerbridge. Altagracia B. Pierre-Outerbridge, in her individual
capacity, Altagracia B. Pierre-Outerbridge, as Administrator of the Estate of
Lindrick Arthur Outerbridge, Altagracia B. Pierre-Outerbridge, as Guardian of the
Property of Andrick A. Outerbridge , as RELEASOR(S), in consideration of the
terms contained herein, received from JENNIE DAVENPORT A/K/A JENNIE
OUTERBRIDGE (“RELEASEE”) on behalf of NATALIE ADAMS, CAMNINE
OUTERBRIDGE, RUBEN OUTERBRIDGE, REESE OUTERBRIDGE, KEITH
OUTERBRIDGE and ELIJAH DAVENPORT (“ADDITIONAL RELEASEES”),
as RELEASEE(S), receipt whereof is hereby acknowledged, releases and
discharges the RELEASEE(S), RELEASEE(S)’ officers, directors, shareholders,

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members, heirs, executors, administrators, successors, attorneys and assigns from
all actions, causes of action, suits, debts, dues, sums of money, accounts,
reckonings, bonds, bills, specialties, covenants, contracts, controversies,
agreements, promises, variances, trespasses, damages, judgments, extents,
executions, claims, and demands whatsoever, in law, admiralty or equity, which
against the RELEASEE(S), the RELEASOR(S), RELEASOR(S)' officers,
directors, shareholders, members, heirs, executors, administrators, successors,
attorneys and assigns ever had, now have or hereafter can, shall or may, have for,
upon or by reason of any matter, cause or thing whatsoever from the beginning of
the world to the day of the date of this AGREEMENT. This release is mutual
between Releasor, Releasee and Additional Releasees on the condition that the
Additional Releasees execute the general release, in the form annexed hereto as
Exhibit 1, and return such executed general release to Outerbridge within thirty
(30) days of the date of this Agreement. If one of the Additional Releasees fails to
execute this general release and return to Outerbridge as set forth herein,
Outerbridge’s release of that Additional Releasee shall be null and void. Davenport
shall ensure that this release has full force and effect but is not responsible for the
actions of the Additional Releasees; and their failure to execute the general release
form in Exhibit 1 shall in no way effect her release to or from the
RELEASOR/Outerbridge.
19. Waiver of Rights Under California Civil Code Section 1542. The Parties expressly
acknowledge that they received the advice of legal counsel concerning the provisions
of California Civil Code section 1542, and that they are familiar with the provisions of
California Civil Code section 1542, which provides as follows:
“A general release does not extend to claims which the creditor or releasing party
does not know or suspect to exist in his or her favor at the time of executing the
release and that, if known by him or her, would have materially affected his or her
settlement with the debtor or released party.”

20. The Parties further acknowledge that they may have sustained damage, loss, cost, or
expense that is presently unknown or unsuspected, and that such damage, loss, cost, or
expense as may have been sustained may give rise to additional damage, loss, cost, or

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expense in the future. Nevertheless, the Parties acknowledge that this Agreement has
been negotiated and agreed upon in light of this situation, and they hereby expressly
waive any and all rights that they have under California Civil Code section 1542, or
under any other state or federal law of similar effect, with respect to the releases
provided herein.
21. Release by Davenport. JENNIE DAVENPORT A/K/A JENNIE
OUTERBRIDGE, as RELEASOR(S), in consideration of the terms contained
herein received from ALTAGRACIA B. PIERRE-OUTERBRIDGE, as
RELEASEE(S), receipt whereof is hereby acknowledged, releases and discharges
the RELEASEE(S), RELEASEE(S)’ officers, directors, shareholders, members,
heirs, executors, administrators, successors, attorneys and assigns from all actions,
causes of action, suits, debts, dues, sums of money, accounts, reckonings, bonds,
bills, specialties, covenants, contracts, controversies, agreements, promises,
variances, trespasses, damages, judgments, extents, executions, claims, and
demands whatsoever, in law, admiralty or equity, which against the
RELEASEE(S), the RELEASOR(S), RELEASOR(S)' officers, directors,
shareholders, members, heirs, executors, administrators, successors, attorneys and
assigns ever had, now have or hereafter can, shall or may, have for, upon or by
reason of any matter, cause or thing whatsoever from the beginning of the world to
the day of the date of this AGREEMENT.
22. Integration of Entire Agreement. This Agreement contains the entire Agreement
of the Parties, and no representations, warranties, inducements or promises not
included herein by express provision or contained in a document or instrument
identified herein and executed contemporaneously herewith shall be binding on any
Party hereto.
23. Counterparts. This Agreement may be signed in counterparts, all of which
together shall constitute a single Agreement. This Agreement shall not be recorded.
Facsimile or Portable Document Format (“PDF”) signature by counsel or the
Parties shall be deemed binding for all purposes thereof, without necessity of an
original signature being thereafter required, and shall have the same force and effect
as an original signed counterpart. Each of the Parties hereby expressly forever

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waives any and all rights to raise the use of a facsimile machine or email to deliver
a signature.
24. Mutually Drafted. This Agreement is to be interpreted without regard to the
draftsman. The terms and intent of this Agreement, with respect to the rights and
obligations of all parties identified in this Agreement, shall be interpreted and
construed on the assumption that all parties participated equally in its drafting.
25. Reliance. Except as expressly set forth herein, the Parties acknowledge that they
have relied solely upon their own judgment, belief and knowledge of the existence,
nature and extent of each claim, demand, or cause of action that each Party may
have against the other(s), and that each such Party has not been influenced to any
extent in entering into this Agreement by any representation or statement regarding
any such claim, demand or cause of action made by any Party hereto. Each Party
also acknowledges that they have consulted with their attorney or have been given
the opportunity to consult with an attorney and knowingly and intentionally waived
said opportunity prior to entering into this Agreement.
26. Governing Law and Jurisdiction: This Agreement and any dispute hereunder
shall be construed pursuant to the laws of the State of New York or California. All
parties agree to submit to the personal jurisdiction of the appropriate state courts of
the State of New York. All parties waive any obligations to such venue being
improper including, without limitation, any claim of forum non conveniens,
provided the action is brought in the City of New York.
27. Waiver: The failure of a party to object to, or the waiver by any party of, one or
more breaches or violations of this Agreement shall not constitute a waiver or
limitation upon the right of such party to object to, or operate or be construed as a
waiver or estoppel of, any other breach or violation of this Agreement. No waiver
by any party of any breach of any right under this Agreement shall be valid u

Case Info

Judge

Roy S. Mahon Track Judge’s New Case

Case No.

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Document Filed Date

April 16, 2024

Case Filing Date

October 11, 2021

County

Parties

Altagracia B Pierre-outerbridge AS ADMINISTRATOR OF the Estate of Lindrick Arthur Outerbridge a/k/a Lindrick Outerbridge, deceased Plaintiff
Camnine Outerbridge Defendant
Elijah Davenport Defendant
Jane Doe Defendant
Jennie Davenport a/k/a Jennie Outerbridge Defendant
John Doe Defendant
Keith Outerbridge Defendant
NELSON, JONATHAN BRETT Attorney for the Defendant
PIERRE-OUTERBRIDGE, ALTAGRACIA BEATRICE Attorney for the Plaintiff
Reese Outerbridge Defendant
Ruben Outerbridge Defendant
SOLOMON FRAGER Attorney
RACHEL LUST Attorneys for Plaintiffs

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