Settlement Agreement

(Breach of Contract)

THIS AGREEMENT made o [Date] between [Name] of [Address] hereinafter referred to as PLAINTIFF, and [Name] of [Address] hereinafter referred to as DEFENDANT, do hereby agree:

The parties have been engaged in litigation before the _______________ County Court Court of _____________, case number ______, styled ______________ vs. _____________ .

On _______________, day of ______________, 20 __, the Court rendered a decision in the matter. The parties desire by this agreement to reach a final and complete settlement of the dispute.

All parties hereto waive the right to file any Motions or other legal process to request that the judgment be modified, vacated or appealed in any way.

In full and complete settlement of the disputes litigated and which could have been litigated, the following settlement shall occur:

Said settlement shall be consummated no later than [date]. The parties shall execute such dismissals as may be required to effect this agreement. In the event that either party fails to consummate the settlement, the parties may apply to the Court stated above to enforce this agreement.

Upon the consummation of the settlement, the parties shall exchange releases in the form attached hereto.

Whether or not specifically required under the terms of this Agree­ment, each party will execute and deliver such documents and take such further actions as may be necessary in order for such party to per­form all of his, her, or its obligations specified herein or rea­sonably implied from the terms hereof.

The terms of the settlement shall be confidential and no party hereto shall reveal the terms of the settlement. However, the parties may state that the matter has been amicably resolved.

Dated: ______________________.

_____________________________.

PLAINTIFF

_____________________________.

DEFENDANT

Reviewed and approved by counsel for :

____________________________

Reviewed and approved by counsel for :

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