COMPROMISE AGREEMENT

This compromise and settlement agreement is made by and

between __________ [name of claimant], (who will be referred to as
plaintiff), whose address is __________, and __________[name of
party against whom claim is made], (who will be referred to as
defendant), whose address is __________.

The parties stipulate to the following:

1. Plaintiff asserts a claim against defendant based on __________

[identify dispute by describing pertinent facts].

2. An action based on this claim is now pending in the Superior Court

of __________ County, case number __________, with plaintiff
represented by attorney __________, and defendant represented by
attorney __________.

3. Defendant denies any liability in connection with the alleged claim.

4. The parties wish to reach a full and final settlement of the action
and all matters arising from the dispute described above.

Therefore, in consideration of the mutual promises set forth, the

parties agree to the following:

a. Defendant will pay to plaintiff $__ [on execution of this agreement

or as the case may be].

b. Plaintiff will execute a Request for Dismissal, dismissing the pending

action with prejudice, and deliver this to the defendant [on execution
of this agreement or as the case may be].

c. Each party releases the other from all rights and claims that they
may have against the other arising from the dispute described above.

d. This agreement is a compromise of a disputed matter and may not

be construed as an admission of any party's liability.

e. This agreement was the result of a negotiated settlement and may

not be construed as having been prepared by any one party.

f. In the event any action is instituted to enforce the provisions of this

agreement, the prevailing party will be entitled to recover attorney
fees.

g. This agreement is intended to bind and benefit the parties, their

heirs, agents, legal representatives, assigns, and successors in
interest.

Dated  
_________ ______________________________
[Signature of Plaintiff]
   
Dated ______________________________
_________ [Signature of Plaintiff's Atty.]
   
Dated ______________________________
_________ [Signature of Defendant]
   
 Dated ______________________________
_________ [Signature of Defendant's Atty.]

Copy furnished the defendant

By registered mail due to
Distance, per affidavit of proof
Of service on next page.

Registry Receipt No.

_________
Date _________

NOTICE

G R E E T I N G S:

Please take note that after your receipt of a copy

of this motion the undersigned will be submitting on
_____________ at 8:30 A.M. without further
arguments nor appearances of counsel.

Copy furnished: