law would result in double recovery because Appellants have recovered full satisfaction for Mrs. Berrios’ injuries. However, under Georgia law, Appellants have not recovered for Mrs. Berrios’ subsequent injury. A “release” is different than a “satisfaction” in that a “satisfaction is an acceptance of full compensation for the injury; a release is a surrender of the cause of action, which may be gratuitous, or given for inadequate consideration.” W. Page Keeton, et al., Prosser and Kee-ton on the Law of Torts § 49 at 332 (5th ed. 1984); Posey, 354 S.E.2d at 419. Here, there is no mention of full satisfac tion for Mrs. Berrios’ injuries in the Release, only a release of claims against the releasees. See, e.g., Oconee Reg’l Med. Ctr. v. Haygood, 217 Ga.App. 600, 458 S.E.2d 400 (1995) (<HOLDING>). The trial court should have applied the
holding that release did not release joint tortfeasor not named therein especially because there was no indication parties intended payment to be full compensation and satisfaction for all injuries holding that a release between two parties cannot bind a thirdparty who was a stranger to the release holding that release unambiguously released defendants from negligence liability even though the release did not include the word negligence because there was no other rational purpose for which the exculpatory language could have been intended holding that release discharges only persons named in or sufficiently described by terms of release holding that release discharges only those tortfeasors specifically named in the release agreement