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Fill and Sign the Martinez Wechsler V Safeco Ins Co of Am Civ 12 0738 Kbmact Form

Fill and Sign the Martinez Wechsler V Safeco Ins Co of Am Civ 12 0738 Kbmact Form

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IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI PLAINTIFFVS. CAUSE NO. DEFENDANT MOTION TO ENFORCE SETTLEMENT COMES NOW Defendant/Counter- Plaintiff and files this his/her motion to enforce settlement and in support thereof would show as follows:Since the filing of this cause the parties have utilized a court appointed special master to assist in resolving all matters complained of in this case. The special master's report has been filed with the court. Subsequent to the filing of the special master's report the parties through counsel have reached an agreement finally resolving all issues of the case. A copy of the correspondence and agreement are attached hereto as Exhibits , , and . For reasons unknown to Defendant the Plaintiff/Counter-Defendant has failed to execute the agreement or permit a final order to be entered in this cause. Defendant respectfully requests this Court enter an order enforcing the settlement agreement attached hereto as Exhibit ---- and further dismissing all claims of this case with prejudice, reasonable attorney fees in bringing this motion and for such other and further relief as the Court deems just and proper.RESPECTFULLY SUBMITTED this the day of 20 . __________________________________ CERTIFICATE OF SERVICE This is to certify that I, Attorney for Defendant, have this day mailed, by United States mail, postage prepaid, a true and correct copy of the above and foregoing MOTION TO ENFORCE SETTLEMENT to: This the day of , 20 . __________________________________

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