The Plaintiff hereby irrevocably releases and forever discharges the Defendant from any future claims arising from the Incident.

The Plaintiff hereby irrevocably and forever waives all rights it may have arising under the law with respect to the Pending Litigation and the above release.

The Parties agree and acknowledge that A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN HIS FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM MAY HAVE MATERIALLY AFFECTED HIS DECISION TO SETTLE.

SETTLEMENT AMOUNT. In consideration for this settlement and release, the Defendant agrees to pay the Plaintiff the amount of [Amount] Dollars ($NUMBER) as full payment, subject to the terms and conditions of this Agreement. Payments shall be made according to the schedule attached hereto as Exhibit A (the “Settlement Payments”).

TIME IS OF THE ESSENCE. The Parties agree and acknowledge that time is of the essence with regard to the Settlement Payments..