Confidential Settlement Agreement Template

This Confidential Settlement Agreement and Release ("Agreement") is entered into on [Date] by and between [Plaintiff/Claimant] and [Defendant/Respondent] (collectively, the "Parties").

1. Settlement Payment

• [Defendant] agrees to pay [Plaintiff] $[Amount] (the "Settlement Amount") within [Number] days of execution, payable via [method].
• No interest unless payment is late; specify penalties for late payment.

2. Release of Claims

• [Plaintiff] releases [Defendant] and affiliates from all claims, known or unknown, arising out of [description of dispute] up to the Effective Date.
• Include waiver of California Civil Code § 1542 (if applicable) or similar statutes.
• Claims excluded: [e.g., obligations under this Agreement, future claims arising after Effective Date].

3. No Admission of Liability

• Settlement is compromise of disputed claims; no admission of wrongdoing.

4. Dismissal of Litigation

• Parties will file stipulation of dismissal with prejudice in [Court] within [Number] days after receipt of Settlement Amount.

5. Confidentiality

• Parties agree to keep terms of Agreement and underlying negotiations confidential, except as required by law, tax advisors, or immediate family (who must maintain confidentiality).
• Public statements limited to mutually agreed language (e.g., "The matter has been resolved").

6. Non-Disparagement

• Parties will not make disparaging statements about each other; carve-out for truthful statements required by law.

7. Taxation and Reporting

• Each party responsible for own tax obligations; specify IRS reporting (Form 1099).
• No representation regarding tax treatment.

8. Enforcement and Remedies

• Breach of confidentiality or non-disparagement may result in injunctive relief and liquidated damages of $[Amount] (if enforceable under local law).

9. Governing Law and Venue

• Agreement governed by laws of [State]; disputes resolved in [court/venue].

10. Entire Agreement and Amendments

• Represents entire understanding; modifications must be in writing signed by all Parties.

11. Counterparts and Electronic Signatures

• Agreement may be executed in counterparts; electronic signatures valid.

12. Effective Date

• Agreement effective upon execution by all Parties and receipt of Settlement Amount (if applicable).

Signatures

[Plaintiff Name]
Signature: ____ Date: __

[Defendant Name]
Signature: ____ Date: __

Approved as to Form:

[Plaintiff’s Counsel] ____ Date: __

[Defendant’s Counsel] ____ Date: __

Consider attaching exhibit detailing payment schedule or mutual releases for related entities.