Per our discussion earlier today, here is some generic settlement language 
you might want to use:

In further consideration of the agreements, covenants and releases set forth 
herein, _____ hereby releases, acquits and discharges ___ and __________, 
together with their directors, officers, employees, agents, attorneys, 
representatives, heirs, assigns, affiliates, and subsidiary and parent 
organizations from and against any and all claims, demands, obligations, 
liabilities, for causes of action, of any nature whatsoever, at law or in 
equity, relating to or arising out of the subject matter of the Pending 
Litigation, including but not limited to, any and all claims, demands, 
liabilities or causes of action asserted in the Pending Litigation or arising 
under any contract or agreement, or in connection with any project, which is 
the subject of the Pending Litigation.

If no lawsuit has been filed, you will need to make some minor adjustments.  
I hope this helps.  Let me know if I can be of further assistance.