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CONFIDENTIAL SETTLEMENT AGREEMENT

This Confidential Settlement Agreement (the "Agreement") is entered into as of [Date] (the "Effective Date") by and between Sarah R Walker ("Walker") and Michael J Turner ("Turner") (collectively, the "Parties").

WHEREAS, the Parties are involved in a legal dispute (the "Dispute");

WHEREAS, the Parties desire to resolve the Dispute fully and finally, without further legal proceedings, on the terms and conditions set forth herein.

NOW, THEREFORE, in consideration of the mutual promises, representations, and warranties contained herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the Parties agree as follows:

1. Settlement Terms

1.1. Payment

Within thirty (30) days of the Effective Date, Turner shall pay to Walker the total sum of $[Amount] (the "Settlement Amount"). The Settlement Amount shall be deemed fully paid upon receipt by Walker of such payment.

1.2. Releases

a. Release by Walker: Upon receipt of the Settlement Amount, Walker hereby irrevocably and unconditionally releases, acquits, and forever discharges Turner, and all of Turner's respective past, present, and future agents, employees, representatives, attorneys, affiliates, successors, and assigns, from any and all liabilities, claims, causes of action, demands, damages, expenses, or costs, whether in law or in equity, whether known or unknown, that Walker ever had, now has, or in the future may have, arising from or in any way related to the Dispute.

b. Release by Turner: Upon receipt of the Settlement Amount, Turner hereby irrevocably and unconditionally releases, acquits, and forever discharges Walker, and all of Walker's respective past, present, and future agents, employees, representatives, attorneys, affiliates, successors, and assigns, from any and all liabilities, claims, causes of action, demands, damages, expenses, or costs, whether in law or in equity, whether known or unknown, that Turner ever had, now has, or in the future may have, arising from or in any way related to the Dispute.

2. Confidentiality

2.1. Non-Disclosure

The Parties agree that the existence, terms, and conditions of this Agreement, and any information relating to the negotiations leading up to this Agreement, shall be held in confidence and shall not be disclosed to any person or entity, except as required by law, regulation, or court order. Moreover, the Parties shall not make any public statements, announcements, or disclosures regarding the Dispute or this Agreement without the prior written consent of the other Party.

2.2. Permitted Disclosures

Notwithstanding the foregoing, the Parties may disclose the existence, terms, and conditions of this Agreement to their respective attorneys, accountants, and financial advisors, provided that they agree in writing to be bound by the confidentiality provisions of this Agreement.

2.3. Breach of Confidentiality

If either Party breaches any of the confidentiality provisions of this Agreement, the non-breaching Party shall be entitled to seek any and all remedies available at law or in equity, including, but not limited to, injunctive relief. The non-breaching Party shall also be entitled to recover from the breaching Party all reasonable attorneys' fees and costs incurred in enforcing these confidentiality provisions.

3. Miscellaneous

3.1. Governing Law

This Agreement, and all matters and disputes arising out of or in connection with this Agreement, shall be governed by and construed in accordance with the laws of the United States, without giving effect to any conflicts of laws provisions that would require the application of the laws of any other jurisdiction.

3.2. Entire Agreement

This Agreement constitutes the entire understanding and agreement between the Parties with respect to the subject matter hereof and supersedes any and all prior or contemporaneous discussions, agreements, or understandings, whether written or oral, related to the subject matter of this Agreement. No modification, amendment, or waiver of any provision of this Agreement shall be effective unless in writing and signed by both Parties.

3.3. Severability

If any provision of this Agreement is found to be invalid or unenforceable by a court of competent jurisdiction, then such provision shall be modified to the extent necessary to make such provision valid and enforceable, and the remainder of this Agreement shall continue in full force and effect.

3.4. Headings

The headings used in this Agreement are for convenience only and shall not affect the construction or interpretation of any provision of this Agreement.

3.5. Counterparts

This Agreement may be executed in one or more counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same instrument.

IN WITNESS WHEREOF, the Parties have executed and delivered this Agreement as of the Effective Date.

______________________________ ______________________________
Sarah R Walker Michael J Turner
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