Settlement Agreement Template

This Settlement Agreement (the “Agreement”) states the terms and conditions that govern the contractual agreement between [Plaintiff] (the “Plaintiff”), and [Defendant] (the “Defendant”) who agrees to be bound by this Agreement.

WHEREAS, INSERT RELEVANT DETAILS (the “Incident”); and

WHEREAS, the Plaintiff and the Defendant agree to settle the matter and avoid any further litigation.

NOW, THEREFORE, In consideration of the mutual covenants and promises made by the parties hereto, the Plaintiff and the Defendant (individually, each a “Party” and collectively, the “Parties”) covenant and agree as follows:

1. DISMISSAL OF PENDING LITIGATION . Within [Time] from the date of this Agreement, the Plaintiff agrees to dismiss or effect dismissal of any claims existing or pending in any jurisdiction relating to the Incident, including the claim filed on [Date] in [Jurisdiction] (the “Pending Litigation”).

2. RELEASE OF FUTURE CLAIMS .

   1. The Plaintiff hereby irrevocably releases and forever discharges the Defendant from any future claims arising from the Incident.

   2. The Plaintiff hereby irrevocably and forever waives all rights it may have arising under the law with respect to the Pending Litigation and the above release.

   3. The Parties agree and acknowledge that A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN HIS FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM MAY HAVE MATERIALLY AFFECTED HIS DECISION TO SETTLE.

3. SETTLEMENT AMOUNT. In consideration for this settlement and release, the Defendant agrees to pay the Plaintiff the amount of [Amount] Dollars ($NUMBER) as full payment, subject to the terms and conditions of this Agreement. Payments shall be made according to the schedule attached hereto as Exhibit A (the “Settlement Payments”).

4. TIME IS OF THE ESSENCE. The Parties agree and acknowledge that time is of the essence with regard to the Settlement Payments.

5.NO MODIFICATION UNLESS IN WRITING. No modification of this Agreement shall be valid unless in writing and agreed upon by both Parties.

6. FULL INTEGRATION. This Settlement Agreement supersedes any prior agreements, understandings, or negotiations, whether written or oral.

7. FURTHER ASSURANCES. The Parties shall make any further assurances as may be necessary to implement and carry out the intent of this Agreement.

8.VENUE. This Settlement Agreement and the interpretation of the terms herein shall be governed by and construed in accordance with the laws of the State of [State]. The Parties irrevocably submit to the exclusive jurisdiction of the federal and state courts located in [County] County, [State].

IN WITNESS WHEREOF, each of the Parties has executed this Debt Settlement Agreement, both Parties by its duly authorized officer, as of the day and year set forth below.

EXHIBIT A

PAYMENT SCHEDULE