JERRY E. SMITH, Circuit Judge:
Francisco Villanueva worked for SHRM Catering Services, Inc. ("SHRM"), aboard an offshore platform owned by Shell Offshore Inc. ("Shell"). He was injured during the course of his employment when a railing he was using to climb stairs gave way. Villanueva filed a third-party complaint against Shell and then, through his attorney, agreed to settle the claim for $18,000. Shell sent Villanueva a letter memorializing the agreement, which...
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