In Mobil Oil Corp. v. Ellender, 968 S.W.2d 917, 927, 41 Tex. Sup. Ct. J. 763 (Tex. 1998), the Court determined that to obtain a dollar-for-dollar settlement credit, Chapter 33 requires only a written election before the case is submitted to the fact finder. 968 S.W.2d at 927 (citing TEX. CIV. PRAC. & REM. CODE 33.014). The Court recognized that Chapter 33 is silent about which party must prove the settlement amount; thus, we referred to the common law. Ellender, 968 S.W.2d at 927. In doing so, the Court concluded that the common law requires only that the record show, in the settlement agreement or otherwise, the settlement credit amount. Ellender, 968 S.W.2d at 927 (relying on First Title Co. v. Garrett, 860 S.W.2d 74, 78 (Tex. 1993)). Once the nonsettling defendant demonstrates a right to a settlement credit, the burden shifts to the plaintiff to show that certain amounts should not be credited because of the settlement agreement's allocation. Ellender, 968 S.W.2d at 928. In Ellender, the Court noted that requiring a nonsettling defendant to prove the settlement agreement's allocation before receiving a settlement credit unfairly penalizes the nonsettling defendant. Moreover, we recognized that settling plaintiffs are in a better position than nonsettling defendants to ensure that the settlement awards are properly allocated. Ellender, 968 S.W.2d at 928).