This Settlement Agreement is entered into as of [Insert Date, Month, and Year] by
and between:
A. XXX, whose address for the purposes of this agreement
shall be [insert address] (hereinafter referred to as “Sammy”)
B. XXX, whose address for the purposes of this agreement shall be
[insert address] (hereinafter referred to as “Irene”)
Sammy and Irene are hereby individually referred to as “Party” and collectively
“Parties”. Sammy and Irene hereby agree to negotiate and settle their [insert
description of what is being settled] under the following terms and conditions:
1. Sammy and Irene agree to dispose and split equally the amount received
from any and all business they had created, including [list the businesses]
during the subsistence of their relationship prior to March, XXX when they
filed a divorce petition.
2. The parties agree that money earned and assets gained by the parties prior to
the date of filing of divorce shall be split equally among the parties.
3. The parties agree that when their matrimonial house is sold, the amount
received from the sale shall be divided equally between the parties, unless the
either party expresses the desire to buy out the other party, upon which the
purchasing party shall pay half of the market value of the house to the other
4. The parties agree to no Alimony or child support in relation to the Children.
The parties agree to abide by the California Stockton directions as regards
shared joint custody of the children.
5. This Agreement for a settlement shall be binding upon all Parties.
6. The Parties agree that upon the signing of this settlement agreement, that
there are no further claims between them of any nature whatsoever from any
and all liability or damages of any kind, known or unknown, in contract or in
tort, related to this agreement.
7. All Parties agree that the other Parties are free from any liability or
wrongdoing. Any liability or wrongdoing is expressly denied. Furthermore, the
Parties each agree that neither Party shall disparage the other to any third
party at any time.
8. The Parties agree that the terms of this Agreement are the result of
negotiations between the Parties and constitute a final accord and satisfaction
concerning all disputes between them related to the outstanding debt
described by this Agreement.
9. This Agreement shall be construed in accordance with the applicable laws in
India. Any dispute arising out of or in connection with this Agreement shall be
subject to the exclusive jurisdiction of the courts at [NAME OF PLACE].
IN WITNESS WHEREOF, the Parties have executed this Settlement Agreement.

SWORN before me this [insert date]
Notary Public
[insert name of notary public, stamp and sign]

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