Plaintiff and Defendant is referred to individually as "Party" and collectively as the "Parties."

This Settlement Agreement (the “Agreement”) is entered into and made valid upon signature by both Parties (the “Effective Date”).

1. Recitals

WHEREAS, Plaintiff  filed legal action against Defendant on [INSERT DATE] concerning [LEGAL ACTION] (the “Lawsuit");

WHEREAS, the Lawsuit was filed in the following court: [INSERT NAME OF COURT]. ;

WHEREAS, the Lawsuit is captioned [INSERT CAPTION], Case No : [INSERT CASE NO]

WHEREAS, as more fully set forth herein, the Parties have agreed to settle their dispute, and intend to fully settle any and all known issues between them arising out of or relating to the Lawsuit;

NOW, therefore, in consideration of the promises and covenants set forth herein, and other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the Parties agree as follows:

1. The Parties agree that the recitals above are all true and correct and accurately represent the Lawsuit. The recitals are incorporated by reference into this Agreement.
   

2. Settlement amount and payment terms:

‍

1. the Defendant shall pay the Plaintiff $[INSERT AMOUNT] (Dollars) (the "Settlement Amount"). The Settlement Amount shall be made in full and final settlement of all Claims, issues, and disputes between the Parties arising from or relating to the Lawsuit.
   

2. The Settlement Amount shall be paid within [INSERT DAYS] days of Defendant  receiving this executed Agreement. 
   

3. Payment of the Settlement Amount shall be made by [Payment form]
   

3. Dismissal:

1. the Plaintiff  agrees to dismiss all Claims in the Lawsuit with prejudice within ten days of receiving the Settlement Amount.
   

4. No admission of wrongdoing:

The Parties acknowledge and agree that nothing contained in this Agreement shall be considered an admission of liability or wrongdoing by Defendant and that this Agreement is purely an act of compromise.

5. Release of claims:

1. The Plaintiff, as well as any representative of such person(s) who has or may have standing to make a claim on that person(s) behalf, be they known or unknown ("the Releasing Parties"), fully and completely release and forever discharge the Defendant and any parents, subsidiaries, related and affiliated companies, predecessors, successors, assigns, present and past, directors, insurers, officers, attorneys, agents, employees, members, managers, shareholders and stockholders, from any and all claims of any kind or nature whatsoever, which were or could have been asserted, now or in the future, against the Defendant arising out of or in any way related to the Lawsuit.
   

2. The Parties expressly acknowledge and agree that this Agreement, and the releases provided herein, are intended to be as broad and inclusive as permitted by law.
   

6. Indemnification:

The Plaintiff will defend, protect, indemnify and hold the Defendant harmless from any and all claims, actions, causes of actions, liabilities, judgments, damages, or expenses of any kind or nature whatsoever (including, but not limited to, attorneys' fees and costs), that are asserted, filed, or prosecuted against Defendant arising out of or relating in any way to the warranties, representations or covenants set forth in this Agreement.

7. Confidentiality:

The Parties hereby expressly agree to keep the terms of this Agreement and the underlying facts relating to the Lawsuit strictly confidential and not disclose the terms and facts to anyone.

8. Attorney's fees and expenses: [If attorney is involved]

The Plaintiff acknowledges that the Settlement Amount is in compromise of the Lawsuit and that all other fees and costs, such as attorney's fees or other expenses, are the responsibility of the Party who incurred such costs.

9. Representations and warranties: 

1. The Plaintiff represents and warrants that the Plaintiff  has the sole and exclusive right and authority to execute this Agreement and receive the Settlement Amount. The Plaintiff warrants that the Plaintiff has not sold, assigned, transferred, conveyed, or otherwise disposed of any of the claims or causes of action released in this Agreement.
   

2. The Parties represent and warrant that they have entered this Agreement without reliance on any promise or representations by any other Party, except those expressly set forth herein.
   

10. Entire agreement:

This Agreement constitutes the entire agreement  between the Parties. This Agreement supersedes and replaces all prior or contemporaneous agreements or understandings, written or oral, regarding the Lawsuit or Settlement Amount.

11. Governing law:

The Parties agree that the state of [INSERT NAME OF STATE] shall govern any matter or dispute relating to or arising out of this Agreement, with the exception of its conflict of law provisions.‍

12. Severability:

If any part or sub-part of this Agreement is held invalid or unenforceable by a court of law or competent arbitrator, the remaining parts and sub-parts will be enforced to the maximum extent possible. In such condition, the remainder of this Agreement shall continue in full force.

13. Modification:

This Agreement may not be modified except in writing, executed by all Parties.‍

14. Advice of counsel:

Both Parties have either received the advice of counsel regarding this Agreement or have waived their right to do so. Both Parties fully understand the contents of this Agreement and agree to it of their own will and accord.