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Mediation Settlement Agreement

A completed mediated settlement recording payment, apology, discontinuance, mutual release, confidentiality and enforcement without admission.

Jurisdiction: England and Wales - completed fictional worked example

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Important: This sample provides general legal information only and is not legal advice. Check the law, prescribed forms and signing requirements that apply to your exact jurisdiction and circumstances before use.

# MEDIATION SETTLEMENT AGREEMENT

Date: 18 April 2029

Parties: Harriet Louise Cole and Redbridge Kitchens Limited

## 1. Parties and purpose

Harriet Louise Cole of 9 Willow Street, Oxford OX2 7QH and Redbridge Kitchens Limited (Company No. 09112233) of 41 Mill Road, Reading RG1 3EU attended a CEDR mediation on 4 April 2029 with mediator Michael Evans FCEDR. The dispute concerned a £28,400 fitted-kitchen contract, alleged defective installation and a disputed final invoice.

## 2. Scope, price and subject

Redbridge will pay Harriet £17,500 by BACS to the account notified in writing within 14 days after this agreement is signed. It will also collect and replace the damaged worktop by 31 May 2029 and reimburse Harriet £650 for reasonable storage costs. Each party bears its own mediation and legal costs, except that Redbridge pays the mediator's £1,200 fee.

## 3. Operating duties

Harriet will provide reasonable access on two business days' notice, accept the replacement worktop as performance of the specified remedial obligation, and file a notice of discontinuance of Oxford County Court claim OC-2029-114 within seven days after cleared payment. Redbridge will give a short written apology acknowledging inconvenience, without admitting legal liability.

## 4. Compliance, records and controls

The payment and obligations are in full and final settlement of all claims, counterclaims and rights of action arising from or connected with the kitchen contract and the dispute, whether known or unknown at signing. The release excludes personal-injury claims not reasonably known at signing, enforcement of this agreement, and rights arising from a later breach.

## 5. Term, ending and remedies

The parties must keep the existence and terms confidential, but may disclose them to their solicitors, accountants, insurers, immediate household members who keep confidence, HMRC where required, or a court or regulator. This agreement is not an admission and remains without prejudice save as to enforcement. Any variation must be signed by both parties.

## 6. Liability and reservations

If Redbridge misses the payment deadline, Harriet may give five business days' written notice and then seek judgment or specific performance for the agreed sum, interest under section 35A of the Senior Courts Act 1981 where available, and reasonable enforcement costs. Failure to provide the replacement permits Harriet to obtain a comparable remedy after notice, crediting any value received.

## 7. Governing law and signatures

This agreement is governed by the law of England and Wales and the courts of England and Wales have exclusive jurisdiction. Harriet and Redbridge's director Aisha Khan sign on 18 April 2029, confirming that each had the opportunity for independent legal advice and that the mediator is not a party or guarantor of performance.

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