Under the new law, there is no distinction between commercial and ordinary partnerships, and solidary liability has been suppressed, so that in all partnerships, each partner is liable only for his virile share. "A 'Solidary obligation' corresponds to a 'joint and several’ obligation in the common law; that is, one for which several debtors are bound in such wise that each is liable for the entire amount, and not merely for his proportionate share.” Black's Law Dictionary at p. 1393 (6th ed. West 1990). 8 . BP insists this argument fails because the contract at § 1.08 clearly and unambiguously states, "Headings are used for convenience only and will not affect the construction or validity of this contract.” See also Sanchez v. Verio, Inc., 119 Fed.Appx. 616, 621 n. 8 (5 th Cir.2004) (<HOLDING>). The Court agrees with BP that Cashman's
holding that the court should review de novo the administrators decision that a property settlement agreement constituted a qdro because it involves interpretation of a settlement agreement and statutory construction not interpretation of the plan recognizing that the standard of review for issues of statutory interpretation and construction is de novo holding that where the parties fail to reach an agreement as to the character nature or type of release to be used an essential element of the agreement is not established 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 recognizing that it is proper to ignore title headings where the contract provides that captions used in the  agreement are inserted for convenience and shall not be deemed a part of the agreement for construction or interpretation