When viewing a facilitator as an advisor rather than a gatekeeper, it was readily apparent that the arbitration agreement contained mutual promises—both the employer and its employees committed to res

Lambert v. Austin Ind., 544 F.3d 1192 (11th Cir. 2008). Reliance on promise to pay. — When a bank had a recorded lien on insured property which was destroyed by fire, and notified the insurer of the bank’s interest, and thereafter the insurer promised to pay to the lienholder any proceeds of the policy of insurance, the bank’s reliance on the promise to pay, and the resulting forebearance of legal action, constituted sufficient consideration to support the insurer’s promise to pay. Georgia Farm Bureau Mut. Ins. Co. v. Alma Exch. Bank & Trust, 195 Ga. App. 103, 392 S.E.2d 320 (1990). Separation agreements. — A separation agreement entered in contemplation of the parties’ uncontested divorce was supported by consideration and was enforceable. Sheppard v. Sheppard, 229 Ga. App. 494, 494 S.E.2d 240 (1997). Promises for Benefit of Third Party Third-party beneficiary can be a stranger to consideration and still maintain action on contract, so long as a valid consideration supports a promise. Hercules, Inc. v. Stevens Shipping Co., 629 F.2d 418 (5th Cir. 1980), rev’d and remanded on other grounds on rehearing, 698 F.2d 726 (5th Cir. 1983). Promise to pay another’s debt, supported by relinquishment of lien on collateral for such debt. — There is sufficient consideration to support agreement to answer for debt of another when creditor is thereby induced by promisor to relinquish valuable lien which creditor had acquired upon property to secure original debt. Bluthenthal & Promises for Benefit of Third Party (Cont’d) Bickart v. Moore, 106 Ga. 424, 32 S.E. 344 (1899). Note given by father for relinquishment of disputed claim against son is enforceable. — While promise by father to assume unenforceable obligation against his minor son is unenforceable, and while promissory note cannot be enforced when the note is executed to pay existing debt of another unless supported by legal consideration, a note voluntarily given by father in liquidation of disputed, and perhaps valid, claim against son, is not without consideration where promisee relinquishes bona fide claim against son, and surrenders evidence thereof. Gibson v. Kyle, 46 Ga. App. 295, 167 S.E. 547 (1932). Assumption of third person’s past-due debt for promise to extend maturity of debt is enforceable. — Written contract in which plaintiff, in consideration of conditional assumption by defendant of past-due indebtedness of third persons, expressly agreed to extend date of maturity of debt, and thereby incurred detriment was not without valuable consideration to defendant. Rice v. Harris, 52 Ga. App. 42, 182 S.E. 404 (1935). Release from employment contract supports third party’s promise to pay released employee’s debt to employer. — Release of laborer from contract of employment is sufficient consideration to support promise of third person to pay debt of laborer to employer. Johnson v. Cothern, 12 Ga. App. 258, 77 S.E. 207 (1903); Wilson v. McDougald Bros. & Co., 12 Ga. App. 74, 76 S.E. 755 (1912). Promise to pay for another’s car repairs, provided promisor allowed to designate garage, lacks consideration. — When only consideration alleged for contract for auto repairs was right given to defendant, employer of tort-feasor, to designate garage at which owner was to have car repaired, and if defendant was not otherwise obligated to repair vehicle, mere choice of place where owner would have the car repaired does not appear to be such consideration as would confer any benefit upon defendant, or any injury to plaintiff, thus alleged agreement to have another’s car repaired at defendant’s expense was unenforceable. Simmons v. Noble, 84 Ga. App. 255, 65 S.E.2d 834 (1951). Promise of note may maintain action although consideration furnished by third party. — When in suit on note it appears that there was consideration to defendant endorser, fact that consideration was furnished by one other than promisee does not prevent promisee from maintaining suit on such note. Edgar v. Edgar Casket Co., 125 Ga. App. 389, 187 S.E.2d 925 (1972).