In BDO Seidman LLP v. Strategic Res. Corp., 70 A.D.3d 556, 896 N.Y.S.2d 15 (1st Dept 2010), a mutual fund's former accountant brought a contribution claim against the fund's former manager. Prior to the action, the fund brought a federal action against the fund manager and an arbitration against the accountant. The fund manager settled with the fund. The settlement agreement required the fund manager to pay the fund a certain amount and release the fund manager from all claims including in the event that the accountant loses the arbitration and seeks contribution from the fund manager. The court held that GOL 15-108 applied as the settlement agreement "unquestionably anticipated that the accountant might make a contribution claim against the fund manager and "the fund manager was attempting to address every possible scenario which might defeat the purpose of the settlement, which was to finally resolve all claims arising out of the fund manager's relationship with the fund." (Id. at 561.)