Settlement Proposal

1. We refer to the above matter, wherein we act for +++, the +++.

2. We also refer to your letter dated +++ and the telephone conversation between +++.

Strictly on a without prejudice basis, we are instructed by our client to propose the following terms and conditions, as full and final settlement of the above matter:-

(a) Our client is agreeable to pay the sum of +++ to your client, as full and final settlement of the above matter (“Settlement Sum”).

(b) The Settlement Sum shall be released to you as the solicitors for your client, as stakeholder on or before +++ subject to the following terms and conditions:-

(i) Your client shall forthwith withdraw +++ upon receipt of the Settlement Sum by you as stakeholder;

(ii) Upon the +++, you may proceed to release the Settlement Sum to your client; and

(iii) Both parties shall bear their own costs in relation to the above matters.

(c) This Settlement constitutes a full final settlement of all claims and/or liabilities between +++ and +++, and all Parties shall have no further claims and/or liabilities whatsoever against each other.

4. Pending negotiation between Parties, we would be grateful if your client can hold +++ in abeyance.

5. We trust you will impress upon your client that our client is prepared to resolve the above matter amicably and we would be grateful if you could revert with your client’s agreement on the above terms within seven (7) days from the date hereof.

6. For the avoidance of doubt, our client expressly reserves all its rights.