Settlement Agreement

A simple settlement agreement, where Plaintiff drops legal action upon Defendant's payment of a fixed amount.

GENERAL RELEASE AND SETTLEMENT AGREEMENT

This General Release and Settlement Agreement (“Agreement”) is made and entered into as of Date (the “Effective Date”), by and between Plaintiff’s full name and Defendant’s full name. (Plaintiff and Defendant are referred to herein collectively as the “Party” or “Parties.”)

WHEREAS, a dispute has arisen between the Parties regarding the briefly describe dispute (the “Dispute”); and,

WHEREAS, the Parties have agreed to resolve the Dispute; and,

WHEREFORE, intending to be legally bound, the Parties hereby agree as follows:

1. Settlement Payment:

a. Defendant shall pay Plaintiff a total of $Final Amount.

2. Mutual Release:

a. In consideration for the Settlement Payment described in paragraph 1 above and other good and valuable consideration, receipt of which is hereby acknowledged, Plaintiff does hereby release, acquit, and forever discharge Defendant from any and all actions, claims, demands, damages, obligations, liabilities, controversies and executions, of any kind or nature whatsoever, whether known or unknown, whether suspected or not, which have arisen, or may have arisen, or shall arise by reason of any matter, cause or thing whatsoever, from the first day of the world, including this day and each day hereafter, and Plaintiff does specifically waive any claim or right to assert any cause of action or alleged cause of action or claim or demand which has, through oversight or error, intentionally or unintentionally or through a mutual mistake, been omitted from this Release.

b. Defendant does hereby release, cancel, forgive and forever discharge Plaintiff and each of her holding companies, subsidiaries, affiliates, divisions, successors, heirs, and assigns in all capacities whatsoever, including without limitation as an officer, director, employee, representative, designee, agent, and shareholder thereof, from all actions, claims, demands, damages, obligations, liabilities, controversies and executions, of any kind or nature whatsoever, whether known or unknown, whether suspected or not, which have arisen, or may have arisen, or shall arise by reason of any matter, cause or thing whatsoever, from the first day of the world, including this day and each day hereafter, and Defendant does specifically waive any claim or right to assert any cause of action or alleged cause of action or claim or demand which has, through oversight or error, intentionally or unintentionally or through a mutual mistake, been omitted from this Release.

3. No Admission of Liability: The Parties agree that nothing contained herein, and no action taken by any Party with respect to this Agreement, shall be construed as an admission of liability.

4. Entire Agreement:

a. This Agreement constitutes the complete understanding between the Parties. No other promises, representations, or agreements shall be binding unless signed by these Parties.

b. This Agreement cannot be altered, amended, or modified in any respect, except by a writing duly executed by all Parties to the Agreement.

5. Severability: In the event that any court of enforcement authority determines that any provision of this Agreement is unenforceable, the provision at issue shall be enforced to the maximum extent permitted by law, and all other provisions shall remain in full effect.

6. Choice of Law: This Agreement shall be governed by and construed in accordance with the laws of the State of Your State without reference to its provisions regarding choice of law.

7. Execution in Counterparts: It is understood and agreed that this Agreement may be executed in identical counterparts and may be transmitted by email or facsimile, each of which shall be deemed an original for all purposes.

8. Authorization to Act: The Parties warrant that they are authorized and empowered to execute this Agreement on their own behalf and on behalf of any person or entity for which they have signed the Agreement.

9. Voluntary Act:

a. The Parties acknowledge that they have read this Agreement and agree to the terms as set forth in it.

b. Further the Parties acknowledge that they have had an opportunity to consult with legal counsel and any other advisers they wish of their own choice with respect to the contents hereof and are signing this Agreement of their own free will.

IN WITNESS WHEREOF, and intending to be legally bound hereby, the Parties have executed the foregoing General Release and Settlement Agreement.

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