This is an agreement between two parties that are currently involved in a lawsuit or
dispute for the settlement of all claims. This agreement sets forth the terms between
two parties for the payment of monetary compensation or some other consideration that
one party furnishes the other in exchange for the forbearance of all claims. This
agreement should be used by small businesses or other entities that are currently
involved in a lawsuit or dispute but want to settle their claims outside the courtroom.
SETTLEMENT OF CLAIM AGREEMENT
This Settlement of Claim Agreement is hereby made on this _________________ day of
_______________, _____________ (the “Effective Date”) by and between
___________________ (“Party 1”) and __________________ (“Party 2”) (the “Agreement”).
WHEREAS, Party 1 and Party 2 desire to settle completely and for all time any and all disputes
or differences between them regarding any matter which arose from or were related to
_____________________________________________ [insert incident that arose to
settlement] (the “Claim”);
NOW, THEREFORE, in consideration of the following covenants and promises and for other
valuable consideration, this Agreement is entered into by the undersigned parties.
ARTICLE 1: THE CLAIM
_____________________________________________ [Detail events giving rise to claim,
including dates, parties, and supporting documents].
ARTICLE 2: SETTLEMENT
Party 1 hereby represents that it has neither filed nor caused to be filed any pending charges,
suits, claims, grievances, or other actions relating to or arising from the Claim detailed above
[OR] Party 1 agrees to immediately dismiss any pending charges, suits, claims, grievances, or
other actions which have already been filed.
Party 1 agrees not to file, pursue or cooperate in the filing or pursuit by any other individual(s)
who may be involved in claims against Party 2, on behalf of Party 1, due to the events detailed
above. Should Party 1 learn of any claims of the type described above, Party 1 shall use its best
efforts to cause such claims to be dismissed, withdrawn, or otherwise terminated.
Party 1 hereby does release, cancel, forgive, and forever discharge Party 2, and each of its
predecessors, parent corporations, holding companies, subsidiaries, affiliates, divisions, heirs,
successors, and assigns, and all of their officers, directors, and employees, 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,
may have arisen, or may arise due to the incidents described above from this day and each day
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hereafter. Party 1 does specifically further waive any claim or right to assert any 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 Agreement.
In consideration of the agreements made by Party 1, Party 2 agrees to _______________
[detail settlement of Party 2, including payment/specific performance/deadlines for payment or
ARTICLE 3: SEVERABILITY
The provisions of this Agreement are to be read as a whole and are not separately enforceable or
severable by either party hereto. This Agreement shall be binding upon the parties, their
successors, assigns, and personal representatives. Neither party shall have any future rights or
ARTICLE 4: ATTORNEYS’ FEES
If judgment is required to enforce the contents of the Agreement, obtain any remedy, or cure any
breach, the non-prevailing party will pay court costs and attorneys’ fees. Each party shall pay its
own attorneys’ fees, if any, incurred in connection with the negotiation and drafting of this
ARTICLE 5: ASSIGNMENT PROHIBITED
Both the Parties are expressly prohibited from assigning this Agreement or any rights or interest
flowing herefrom. Assignment will only be valid with the express written consent of both
ARTICLE 6: GOVERNING LAW
This Agreement shall be interpreted and enforced under the laws of the State of