In Sime v. Malouf (1949) 95 Cal.App.2d 82, the court considered several factors to determine whether a release that was executed in connection with one joint venture transaction should also embrace and bar related claims that arose later (for fraud and conspiracy to defraud by other members of the venture). The court determined that the fraud claim arose in connection with a different transaction, separate from the joint venture relationship. That joint venture had been terminated when the plaintiff sold his interest in it, but he claimed defendants had failed to meet their duty to inform him of its real value. The release accordingly was limited to claims arising out of the closing of the joint venture (such as an accounting). It did not include independent allegations of fraud to induce the sale of the joint venture interest, and it could not be interpreted as a general release that would have barred claims that were then unknown to the plaintiff, which he could not have intended to release. (Id. at pp. 109-110.)