from claims of misfeasance is void as a matter of statute. Section 310 of the Companies Act of 1985 provides that “any provision ... in any contract with the company or otherwise,” which purports to exempt a director from liability for “negligence, default, breach of duty or breach of trust” in relation to an English company, is void. While the Companies Act of 1985 expressly applies to English companies, courts must construe the release in accordance with English law. The statute appears to apply here — despite Gulfs incorporation in the United States. English common law provides that releases will not be construed to apply to facts of which the releasing party is unaware at the time of entering the agreement. See Ecclesiastical Comm’n for England v. N.E. Ry, 4 Ch.D. 845 (1877) (<HOLDING>). As we held above, the record does not
holding that inclusion of a general release was merely a suggestion of how to terminate the lawsuit and that acceptance was not qualified on use of the specific release and party was willing to discuss the terms of a release holding that a release of unknown claims has no effect in the absence of evidence apart from the words of the release holding that release discharges only those tortfeasors specifically named in the release agreement holding that release did not bar plaintiffs claim because plaintiff had no ground to suspect that act complained of had taken place when giving release holding the district courts revocation of defendants term of supervised release did not end the courts jurisdiction over defendants release