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Claim Settlement

____________________, referred to herein as the First Party, and _______________, referred to as the Second Party, agree:

That the parties have a potential claim dispute.

In full and complete settlement of any and all claims under the laws of any applicable jurisdiction, First Party shall pay $____________ to Second Party related to or arising from the claim referred to herein. Said settlement shall also include any attorney’s fees or claim/litigation expenses.

This release shall also inure to the benefit of _____________________.

This release shall be contingent upon the approval of the ________________. Upon final approval, which shall be defined as an approval for which no further review is possible, payment shall be made. In the event that the settlement is not approved this agreement shall be void and of no effect.

READ CAREFULLY. THIS IS A FINAL AND BINDING AGREEMENT AND WAIVER OF ALL FUTURE RIGHTS. UPON PAYMENT THE SECOND PARTY WILL HAVE NO FUTURE RIGHTS.

This is the entire agreement between the parties and may only be varied by a writing executed by the parties.

Dated: ___________________

____________________________________

First Party

____________________________________

Second Party