In Vogel v. Wells (1991), 57 Ohio St.3d 91, 93, 566 N.E.2d 154, the Ohio Supreme Court has established that Mary Carter agreements are generally characterized by three basic provisions: "'First, the settling defendant guarantees the plaintiff a minimum payment, regardless of the court's judgment. Second, the plaintiff agrees not to enforce the court's judgment against the settling defendant. Third, the settling defendant remains a party in the trial, but his exposure is reduced in proportion to any increase in the liability of his codefendants over an agreed amount. Some Mary Carter agreements include a fourth element: that the agreement be kept secret between the settling parties.'" The court upheld the lower court's refusal to disclose an alleged Mary Carter agreement between the plaintiff and one defendant, where it found that an offer to limit the plaintiff's execution of the judgment against the "settling" defendant's property was gratuitous. 57 Ohio St.3d at 94. According to the court, the likelihood for potential bias on the part of the settling defendant was minimal, and the record did not indicate any collusive conduct between the agreeing parties. Id.