__________________, referred to as PLAINTIFF, and _________________, referred to as DEFENDANT, agree:
The parties have been engaged in litigation before the _____________Court of ___________, case number ____________, styled _________________ vs. ___________________.
On _________________, 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:….
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