credit not only unfairly penalizes the nonsettling party but also allows settling parties to abrogate the one satisfaction rule. See Hess Oil Virgin Islands Corp. v. UOP, Inc., 861 F.2d 1197, 1208 (10th Cir.1988); United States Indus., 854 F.2d at 1262. Settling parties could prevent nonsettling parties from receiving settlement credit by refusing to allocate between actual and punitive damages in settlement agreements. See United States Indus., 854 F.2d at 1262. The better rule is to require a settling party to tender to the trial court, before judgment, a settlement agreement allocating between actual and punitive damages as a condition precedent to limiting dollar-for-dollar settlement credits to settlement amounts representing actual damages. Accord Howard, 674 F.2d at 351 (<HOLDING>). Therefore, we hold that to limit a
holding that a defendant cannot receive credit for settlement amounts representing punitive damages which are not common damages but are individual in nature holding that the insurer was entitled to credit against the owners claim in the amount paid to the mortgagee holding that the defendant was entitled to a credit equaling the full amount of the settlement when the plaintiff conceded that the agreement did not indicate whether it covered punitive damages recognizing that the plaintiff conceded that the jury presumably awarded the full amount of cure he requested holding that a plaintiff could recover actual damages under the tcpa for loss of credit if the plaintiff submitted sufficient proof of the amount damages requested