Confidential Settlement, Separation, And Release Agreement printable pdf download

[EMPLOYMENT CASE]

CONFIDENTIAL SETTLEMENT, SEPARATION, AND RELEASE AGREEMENT

This Confidential Settlement, Separation, and Release Agreement (“Settlement

Agreement”) is entered into as of _____________, ____, (the “Effective Date”) by and between

Jane Employee (“Plaintiff”) and XYZ Corp. (“XYZ”).

RECITALS

WHEREAS, Plaintiff filed a lawsuit against XYZ on ______________, ____

which is currently pending in the _________________________ Court, is entitled Employee v.

XYZ Corp., and bears Case No. _________________(“Lawsuit”); and,

WHEREAS, Plaintiff and XYZ (collectively the “Parties”) negotiated a settlement

effective ___________; and,

WHEREAS, the Parties desire to resolve the claims asserted in the Lawsuit on the

terms set forth in this Confidential Settlement and Release Agreement ("Settlement

Agreement"); and,

WHEREAS, the Parties have agreed that it is in their mutual interest to terminate

their employment relationship such that Plaintiff shall no longer be employed by XYZ or any of

its subsidiaries, related entities, or successors, as more fully set forth hereinafter;

NOW THEREFORE, in consideration of the mutual promises made herein, the Parties

hereby agree as follows:

AGREEMENT

XYZ's Obligations. XYZ shall pay to the total sum of

________________________________ ($__________) (“Settlement Payment”) within three (3)

weeks of the receipt by counsel for XYZ of the executed Settlement Agreement and W-9 forms

from Plaintiff and her attorneys. XYZ shall issue checks for the Settlement Payment as follows:

1) one check made out to "Jane Employee " in the amount of _______________ ($__________)

less applicable withholdings, for lost wages; 2) a second check made out to “Jane Employee” in

the amount of __________________________ ($__________) reported via 1099 in order to

compensate plaintiff for her claims of non-economic damages, including emotional distress; and

3) a third check made out to “Plaintiff’s Law Firm” in the amount of ___________________

($___________) reported via 1099 in order to compensate plaintiff’s counsel for a portion of its

attorney’s fees. All three checks shall be delivered to the law firm of “Plaintiff’s Law Firm.”

Dismissal by Plaintiff. Plaintiff shall, within five days of execution of this

Settlement Agreement, execute and deliver to counsel for XYZ a completed Request for

Dismissal with Prejudice of the Lawsuit. Upon XYZ’s mailing of the Settlement Payment to

Confidential Settlement, Separation, And Release Agreement