demonstrates that there is no consensus on the issue. Compare Reynolds v. Amchem Prods., Inc., 32 A.D.3d 1268, 1269, 822 N.Y.S.2d 216 (2006) (“Absent evidence of collusion between the co-defendant and plaintiffs to the detriment of the company, the failure to disclose the high-low agreement did not mandate reversal.”), Monti v. Wenkert, 2006 WL 3908564, *14, 2006 Conn.Super. LEXIS 3849, 45-6 (Conn.Super.Ct.2006) (In upholding use of high-low agreement without disclosure to nonset-tling defendant: “If the true alignment of the codefendants is apparent to the parties, the court and the jury, introduction of the agreement to the jury is unnecessary because there is no prejudice to be avoided.”), and Ziegler v. Wendel Poultry Seros., Inc., 67 Ohio St.3d 10, 17, 615 N.E.2d 1022 (Ohio 1993) (<HOLDING>), with Hashem, v. Les Stanford Oldsmobile,
holding highlow settlement agreement between estate and company was not a mary carter agreement and it was not erroneous to have allowed the company to participate in the trial or by failing to disclose the agreement to the jury holding that a settlement agreement is not a court order and therefore a violation of the settlement agreement would not subject a party to contempt holding that where one party had received a written agreement and conformed his conduct to that agreement for an extended period of time but failed to sign the agreement he was equitably estopped from denying the validity of the agreement holding that plaintiffs personal injury action against other driver in auto accident was not precluded by arbitration award between insurance carriers regarding damage to plaintiffs car because plaintiff did not participate in or control arbitration was not a party to arbitration agreement did not adopt agreement or attempt to benefit from agreement holding that the plaintiffs lawsuit which was filed despite a general release in the parties settlement agreement constituted a material breach of the settlement agreement