Confidential Settlement Agreement and Mutual Release Sample Contracts

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CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • March 17th, 2016 • Lmi Aerospace Inc • Aircraft parts & auxiliary equipment, nec

This Settlement Agreement (hereinafter “Agreement”) is made and entered into as of this 5th day of November, 2015, by and between Tech Investments, LLC, Tech Investments II, LLC, (collectively "Tech Investments" or "Plaintiffs"), Charles M. Newell, in his individual capacity ("Newell"), Charles M. Newell, in his capacity as Sellers’ Representative, as that term is defined in the “Membership Interest Purchase Agreement Among LMI Aerospace, Inc., Valent Aerostructures, LLC (“Valent”) and its Members dated December 5, 2012” (the “Purchase Agreement”1), Henry H. Newell, in his individual capacity ("Henry H. Newell"), and LMI Aerospace, Inc. (hereinafter "LMI" or "Defendants") (all collectively the "Parties"), all of whom contract and agree as follows.

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • December 1st, 2020 • Progenity, Inc. • Services-medical laboratories • Minnesota

This Settlement Agreement and Mutual Release (the “Agreement”) is entered into as of September 30, 2019 (the “Effective Date”), by and among United HealthCare Services, Inc. and UnitedHealthcare Insurance Company (collectively, with their affiliates and subsidiaries, “United”), and Progenity, Inc. (“Progenity”). Each party to this Agreement is referred to as a “Party” and together as the “Parties.”

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • December 15th, 2005 • Atsi Communications Inc/De • Telephone communications (no radiotelephone) • Texas

ATSI Communications, Inc., a Nevada corporation (“ATSI”), formerly a Delaware corporation, and TELEMARKETING DE MEXICO S.A DE C.V., a Mexican Corporation, (“TELEMARKETING”) (collectively, the “Parties”), hereby enter into this Confidential Settlement Agreement and Mutual Release (the “Settlement Agreement”).

Pursuant to 17 CFR 20.24b-2, confidential information has been omitted in places marked “***” and has been filed separately with the Securities and Exchange Commission pursuant to a Confidential Treatment Request with the Commission. CONFIDENTIAL...
Confidential Settlement Agreement and Mutual Release • November 9th, 2018 • Rockwell Medical, Inc. • Electromedical & electrotherapeutic apparatus • Michigan

This Settlement Agreement and Mutual Release (the “Agreement”) is made this 7th day of August, 2018 (the “Execution Date”), by and among Rockwell Medical, Inc. (“Rockwell” or the “Company”), Robert Chioini (“Chioini”), Thomas Klema (“Klema”), Patrick Bagley (“Bagley”), and Ronald Boyd (“Boyd”). Rockwell, Chioini, Klema, Bagley and Boyd are together referred to herein as the “Settling Parties”. Benjamin Wolin (“Wolin”), Mark Ravich (“Ravich”), John Cooper (“Cooper”), Robin Smith (“Smith”) and Lisa Colleran (“Colleran”) (Wolin, Ravich, Cooper, Smith, and Colleran are collectively referred to as the “Director Defendants”) are also executing this Agreement, but only with regard to the obligations in Paragraphs 5, 12, 13 and 17.

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • October 2nd, 2015 • Alnylam Pharmaceuticals, Inc. • Pharmaceutical preparations • Massachusetts

This Confidential Settlement Agreement and Mutual Release (“Confidential Settlement Agreement”) is entered into as of the Effective Date by and between Max-Planck-Gesellschaft zur Förderung der Wissenschaften e.V. (“MPG”), Max-Planck-Innovation GmbH (“MI”) (collectively referred to herein as “Max Planck”), and Alnylam Pharmaceuticals, Inc. (“Alnylam”), on the one hand, and Whitehead Institute for Biomedical Research (“Whitehead”), Massachusetts Institute of Technology (“MIT”), and the University of Massachusetts (“UMass”), on the other hand.

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • August 14th, 2014 • Cyalume Technologies Holdings, Inc. • Electric lighting & wiring equipment • Massachusetts

This Confidential Settlement Agreement and Mutual Release (this “Agreement”), is made July 10, 2014 (the “Effective Date”), between Cyalume Technologies, Inc., (“Cyalume”) and Cyalume on behalf of Emil Jachmann (“Jachmann”), in the first instance, and Omniglow LLC, (“OmniGlow”), Randye M. Holland and Stanley M. Holland as Trustees of the Randye M. Holland and Stanley M. Holland Trust and the Leemon Family LLC, in the second instance, (individually sometimes referred to as a “Party” and collectively as the “Parties”).

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • November 12th, 2004 • Troy Group Inc • Services-computer integrated systems design • California

This Confidential Settlement Agreement and Mutual Release (the "Settlement Agreement") is made and entered into by and between TROY Group, Inc., a Delaware corporation, Dirk, Inc., a Delaware corporation, the Dirk Family Trust, Westar Capital LLC, a limited liability company, Robert Messina, an individual, and Del Conrad, an individual (each individually, a "Party" and collectively, the "Parties"). This Settlement Agreement is made in light of the following Recitals:

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • April 19th, 2017 • Puget Technologies, Inc. • Textile mill products • New York

This Confidential Settlement Agreement and Mutual Release (“Agreement”) is entered into by and between ADAR BAYS LLC (“ADAR”), to the benefit of Samuel Eisenberg and Sarah Eisenberg, each in their personal capacity, PUGET TECHNOLOGIES, INC. (“PUGET”), HERMANN C. BURCKHARDT (“Burckhardt”), and THOMAS A. JASPERS (“Jaspers,” together with Burckhardt and Puget, the “Puget Parties” and together with ADAR, the “Parties”).

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • September 9th, 2022 • Solar Integrated Roofing Corp. • Construction - special trade contractors • Nevada

This Confidential Settlement Agreement and Mutual Release (“Agreement”), effective as of the date this Agreement is fully executed (“Effective Date”), is made and entered into by and between Solar Integrated Roofing Corp, a Nevada corporation (“SIRC”) and Cornerstone Construction Team, LLC (“CCT”), on the one hand, and Hunter Ballew (“Ballew”), Upward Holdings Group, LLC (“Upward”), and Roofcon, LLC (“Roofcon”), on the other hand. At times and where appropriate, SIRC, CCT, Ballew, Upward, and Roofcon, are collectively referred to as the “Parties” and each, individually, as a “Party.”

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • July 22nd, 2010 • Masimo Corp • Electromedical & electrotherapeutic apparatus • Delaware

This Confidential Settlement Agreement and Mutual Release (the “Agreement”) dated as of the 13th day of July, 2010 (the “Effective Date”), is made and entered into by and between Hygia Health Services, Inc., an Alabama corporation (“Hygia”), and Masimo Corporation, a Delaware corporation (“Masimo”) (collectively, Hygia and Masimo are referred to as “Parties” and with respect to each of them a “Party”).

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • March 31st, 2005 • Vita Food Products Inc • Miscellaneous food preparations & kindred products • Delaware

This Settlement Agreement and Mutual Release (the “Agreement”) is entered into this 28th day of March, 2005, by and among Vita Food Products, Inc. (“Products”), Vita Specialty Foods, Inc. (formerly known as Vita Holdings, Inc.) (“Specialty”), Virginia Honey Company, Inc. (“Honey”), The Halifax Group (“Halifax”) (collectively, Products, Specialty, Honey and Halifax and all affiliates thereof shall be referred to as “Vita”), and Robert J. Budd (“Budd”).

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • May 17th, 2011 • Lectec Corp /Mn/ • Electromedical & electrotherapeutic apparatus • Texas

This Settlement Agreement and Mutual Release (“Agreement”), effective as of the date of the last signature appearing below (“Effective Date”), is by and between LecTec Corporation, a Minnesota corporation, having a principal place of business at 1407 South Kings Highway, Texarkana, Texas 75501 (‘‘LecTec’’), and Chattem, Inc., a Tennessee corporation with its principal place of business at 1715 W. 38th Street, Chattanooga, Tennessee 37409 (“Chattem”). LecTec and Chattem are sometimes referred to herein individually as a “Party” and collectively as “Parties.”

CERTAIN INFORMATION IDENTIFIED WITH [***] HAS BEEN EXCLUDED FROM THIS EXHIBIT BECAUSE IT IS BOTH (I) NOT MATERIAL AND (II) IS OF THE TYPE THAT THE REGISTRANT TREATS AS PRIVATE OR CONFIDENTIAL. CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • October 10th, 2023 • E2open Parent Holdings, Inc. • Services-computer processing & data preparation • New York

This Confidential Settlement Agreement and Mutual Release (the “Settlement Agreement”) is entered into as of September 14, 2023 (the “Settlement Date”), by and between [***] (“Claimant”), and BluJay Solutions Ltd., f/k/a Kewill Inc. (“Respondent”). Claimant and Respondent may be referred to herein individually as a “Party” or collectively as the “Parties”.

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • July 7th, 2022 • Insignia Systems Inc/Mn • Services-advertising • Minnesota

This Confidential Settlement Agreement and Mutual Release (“Agreement”) dated as of July 1, 2022, is made by and between Plaintiff Insignia Systems, Inc. (“Plaintiff”), and Defendants News Corporation, News America Marketing In-Store Services L.L.C., and News America Marketing FSI L.L.C. (collectively, “Defendants”). Plaintiff and Defendants are collectively referred to herein as the “Parties.”

Contract
Confidential Settlement Agreement and Mutual Release • May 5th, 2020 • Massachusetts

EX-10.2 3 b85475exv10w2.htm EX-10.2 Confidential Materials omitted and filed separately with the Securities and Exchange Commission. Asterisks denote omissions. Exhibit 10.2 CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE This Confidential Settlement Agreement and Mutual Release (“Confidential Settlement Agreement”) is entered into as of the Effective Date by and between Max-Planck-Gesellschaft zur Förderung der Wissenschaften e.V. (“MPG”), Max-Planck-Innovation GmbH (“MI”) (collectively referred to herein as “Max Planck”), and Alnylam Pharmaceuticals, Inc. (“Alnylam”), on the one hand, and Whitehead Institute for Biomedical Research (“Whitehead”), Massachusetts Institute of Technology (“MIT”), and the University of Massachusetts (“UMass”), on the other hand. This Confidential Settlement Agreement is made with respect to the lettered recitals below. The Definitions set forth in Section 1 below apply to the recitals. A. MPG, MI, Alnylam, Whitehead, MIT, and UMass are parties to the

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • June 14th, 2022 • Track Group, Inc. • Communications equipment, nec • New York

This Confidential Settlement Agreement and Mutual Release (“Agreement”) is entered into by and among Eli Sabag (“Sabag”), Track Group, Inc. (“Track”), Sapinda Asia Limited (Sapinda), and Lars Windhorst (with Sapinda, jointly, “Windhorst”) (Collectively, “Parties”).

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • October 18th, 2021 • Oklahoma

In consideration of the commitments set forth below, the City of Broken Arrow (“City”) Contech, Inc. (“Contech”) and Employers Mutual Casualty Company (“EMCC”), enter into this Confidential Settlement Agreement and Mutual Release (“Agreement”). The foregoing entities are sometimes referred to herein individually as a “Party” or collectively as the “Parties.”

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • August 6th, 2018 • EVO Transportation & Energy Services, Inc. • Retail-auto dealers & gasoline stations • Minnesota

This Confidential Settlement Agreement and Mutual Release (“Agreement”), is made and entered into as of July 31, 2018 (the “Effective Date”), by and among Red Ocean Consulting, LLC, a Florida limited liability company, Brenton Hayden, Richard H. Enrico Revocable Trust Dated June 9, 1998, and Richard H. Enrico (collectively, the “Creditors”), on the one hand, and Titan CNG, LLC, a Delaware limited liability company, Titan El Toro, LLC, a Delaware limited liability company, Titan Diamond Bar, LLC, a Delaware limited liability company, Titan Blaine, LLC, a Minnesota limited liability company, Kirk Honour, Scott Honour, John Yeros, Minn Shares Inc., now known as EVO Transportation & Energy Services, Inc., a Delaware corporation (collectively, the “Debtors”), on the other hand. The Creditors and the Debtors are collectively referred to herein as the “Parties.”

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • April 3rd, 2006 • Evans & Sutherland Computer Corp • Miscellaneous electrical machinery, equipment & supplies • California

This Confidential Settlement Agreement and Mutual Release (hereinafter “Agreement”) is made as of this 28th day of December, 2005, by and between Evans & Sutherland Computer Corp. (hereinafter collectively “E&S”) on the one hand, and Federal Insurance Company (hereinafter “Federal”) on the other. E&S and Federal shall be referred to collectively as “Parties” and each will be referred to singularly as “Party.”

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • July 7th, 2023 • Reliance Global Group, Inc. • Insurance agents, brokers & service • Florida

This Confidential Settlement and Mutual General Release Agreement (this “Agreement”) is entered into effective as of June 30th, 2023 (the “Effective Date”) by and among (i) Reliance Global Group, Inc. (“RGG”), (ii) Medigap Healthcare Insurance Agency, LLC (“Agency,” and, together with RGG, the “Reliance Parties”), (iii) Pagidem, LLC f/k/a Medigap Healthcare Insurance Company, LLC (“Pagidem”), (iv) Joseph J. Bilotti, III (“Bilotti,” and, together with Pagidem, the “Bilotti Parties”), (v) Kyle Perrin (“Perrin”), (vi) Zachary Lewis (“Lewis”), (vii) T65 Health Insurance Solutions, Inc. f/k/a T65 Health Solutions, Inc. (“T65”), and (viii) Seniors First Life, LLC (“SFL,” and, together with Lewis and T65, the “Lewis Parties”). The Bilotti Parties, Perrin, and the Lewis Parties are collectively referred to herein as the “Medigap Parties.” Each of the parties shall be referred to individually as “Party,” and collectively referred to as the “Parties.”

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • March 29th, 2022

This Confidential Settlement Agreement and Mutual Release (this “Agreement”) is entered into by Conference USA (the “Conference”); Marshall University (“Marshall”), the University of Southern Mississippi (“USM”), and Old Dominion University (“ODU”) (Marshall, USM, and ODU collectively, the “Universities,” each of the Conference and the Universities a “Party,” and, collectively, the “Parties”), through their respective authorized representatives.

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CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Confidential Settlement Agreement and Mutual Release • November 7th, 2016 • Horizon Pharma PLC • Pharmaceutical preparations • Delaware

This Confidential Settlement Agreement and Mutual Release (this “Agreement”) is entered into as of September 26, 2016 by and between (a) EXPRESS SCRIPTS, INC. (“EXPRESS SCRIPTS”) and (b) HORIZON PHARMA USA, INC., (“HORIZON”). Collectively, EXPRESS SCRIPTS and HORIZON shall be referred to as the “Parties” or singularly, a “Party.”

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