WILKINSON, Circuit Judge:
John Jones was injured in an automobile accident with Pamela Brown on May 3, 1983. He subsequently settled with his and Brown's insurance companies and orally agreed to release Brown from any further liability arising from the accident. Because the release was not given in writing as required by Va.Code Ann. § 8.01-35.1 (1950) (1988 cum. supp.), that provision, which holds joint tort-feasors liable, is inapplicable. Since the release...
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