THE MEDIATION RULES OF CHICAGO INTERNATIONAL DISPUTE RESOLUTION ASSOCIATION (CIDRA) ARTICLE 22 - SETTLEMENT 1) If a settlement is reached, counsel for the parties will draft a written settlement document incorporating all settlement terms, which may include mutual releases from all liability relating to the subject matter of the dispute. This draft will be circulated among the parties, amended as necessary, and formally executed. Initially, a preliminary memorandum of understanding may be prepared at the mediation conference and executed by the parties. 2) If litigation is pending, the settlement may provide that the parties will request dismissal of the case promptly upon execution of the settlement agreement. The parties also may request the court to enter the settlement agreement as a consent judgment.