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You need to type up an agreement that states, "Your name and His name, now agree that in exchange for valuable consideration which they both acknowledge hereby voluntarily agree without any admission of liability to settle any and all claims, know or unknown at the time of this agreement. In exchange for good and valuable consideration paid by your name to his name, his name agrees to withdraw and forever dismiss any claims against you with any state or federal agency and waives any claims that may or may not have been brought in any court in the United States against you for any claims arising out of your engagement with him as an independent contractor."