Confidential Mediated Settlement Agreement Form printable pdf download

_______________________________

___________________________________

Cause No. ________________________

Confidential Mediated Settlement Agreement

The above-referenced cause was convened for mediation on ____________________,

with all parties participating personally and/or by and through authorized representatives and

through counsel. The parties made the following agreements, and agree that the following

terms of this settlement shall remain confidential:

______________________________ agrees to accept, and __________________________

agrees to pay, the total sum of $_______________________, in full and final settlement of all

disputed claims in the above-referenced litigation. The settlement proceeds shall be tendered no

later than ___ days from the date of this agreement [on or before __________ ].

Defendant shall issue payment of the settlement proceeds by separate checks to Plaintiff and

Plaintiff’s counsel’s law firm, amounts to be provided by Plaintiff’s counsel. [Defendant shall

issue appropriate, separate 1099’s, to the extent allowed by law to do so.]

[Defendant shall, in the future, in response to any appropriate inquiry regarding Plaintiff’s

employment with Defendant, indicate the dates of Plaintiff’s employment, her job, title, her

compensation, and that she is eligible for rehire.]

The parties contemplate the preparation of more detailed settlement documents which will

contain a full, complete, mutual and general releases by the parties of each other, and an agreed

order of dismissal, with prejudice, of all claims in the above-referenced lawsuit. The final

settlement documents will include a provision preserving the confidentiality of the terms of this

settlement agreement, [and a mutual non-disparagement clause,] [with a liquidated damages

provision of $____________________ for a proven violation of the confidentiality/non-

disparagement clauses.]

In any proceeding in which one party alleges violation of the

confidentiality and/or non-disparagement clause, the prevailing party shall be entitled to

recovery of its fees and expenses.

·The parties agree to pay their own attorney's fees and costs, except as set forth above.

·In the event there is any dispute over the terms of the final settlement documents or the

consummation of this agreement, the parties agree to submit the dispute to non-binding

mediation before a mediator to be agreed upon by the parties, or failing agreement, appointed by

the Court.

Confidential Mediated Settlement Agreement Form