Mutual Release for West Palm Beach Florida car accident 1-800-74-TRIAL

1. This Mutual Release and Settlement Agreement (the “Agreement”) is made and entered into by John Doe (“Doe” or “Plaintiff”) and XYZ Corporation (“XYZ” or “Defendant”).
2. The Agreement is made in reference to the lawsuit filed by Plaintiff against Defendant in the United States District Court for the District of Massachusetts entitled Doe v. XYZ Corporation, Civil Action No. 2001-195(CLJ) (the “Litigation”).
3. As partial consideration for the release of all claims asserted by Plaintiff in the Litigation against Defendant, Defendant agrees to make the following payments to Plaintiff on execution of the Agreement: Defendant agrees to pay Plaintiff a lump sum cash amount of $850,000 and an attorney’s fee in the amount of $300,000 (collectively, the “Payment”). The Payment is to be made by cashier’s check on or before [insert date]. The Payment is partial consideration because the releases referred to below are also consideration for the Payment.
4. Except for the above obligations of XYZ to make the Payment to Plaintiff, (West Palm Beach Florida car accident Plaintiff), for himself, his predecessors, successors, heirs and assigns, releases and absolutely and forever discharges XYZ and its insurers, sureties, attorneys, predecessors, successors and assigns, of and from any and all claims, demands, damages, debts, liabilities, accounts, reckonings, obligations, costs, expenses, liens, actions and causes of action of ever kind and nature whatsoever that were made or that could have been made in the Litigation and more specifically any allegations that XYZ failed to maintain its premises in a reasonable and safe manner, and any damages or injuries that (West Palm Beach Florida car accident Plaintiff) claims resulted there from, whether now known or unknown, suspected or unsuspected, which (West Palm Beach Florida car accident Plaintiff) now has, owns, or holds or at anytime heretofore ever had, owned or held as of the date of the Agreement.
5. (West Palm Beach Florida car accident Plaintiff) understands and expressly agrees that acceptance of the Payment is in full accord and satisfaction of the disputed claims, that the Payment is not an admission of liability by XYZ, and that XYZ expressly denies any liability to (West Palm Beach Florida car accident Plaintiff).
6. (West Palm Beach Florida car accident Plaintiff) further agrees that the amounts of the Payment and the terms and conditions of settlement shall remain confidential and shall not be disclosed by (West Palm Beach Florida car accident Plaintiff) or Defendant to any third person or entity, except disclosure may be made by them to their respective accountants, auditors, attorneys and tax advisers, or as may be required by law upon the order of a court of competent jurisdiction. Notwithstanding the confidentiality of the payment of the terms and conditions of settlement, the parties may disclose and acknowledge the fact that the disputes between them in the Litigation have been mutually resolved and settled. Upon receipt of the Payment, the parties shall cause the Litigation to be dismissed with prejudice and with no costs or expenses.
7. The Agreement shall be governed by and construed in accordance with the laws of the Commonwealth of Massachusetts without regard to its conflict of laws provisions. Any action brought to enforce the Agreement or to construe its terms, or to determine the rights of the parties shall be brought in the federal or state courts of Massachusetts.
8. The Agreement shall be considered drafted by each of the parties for purposes of the construction, interpretation and enforcement.
9. The Agreement may be executed in counterpart signatures, each of which shall be deemed an original.

(West Palm Beach Florida car accident Plaintiff), John Doe XYZ Corporation

By its:
Date: Date: