Start with the actual business goal
A landlord may value a reliable turnover date, payment, a release, or avoiding further disruption. Identify the priority before making a proposal. Compare the proposed terms with the costs and uncertainty of continuing the dispute, using facts from the actual matter.
Put the moving pieces in writing
Ask counsel to address who must leave, the surrender deadline, keys and access devices, the condition of the premises, and any property left behind. Specify how payments are made, what happens to the deposit, and which obligations remain after surrender. Do not assume a payment alone resolves a pending case.
Make the release and the money fit
Identify who gives a release, who receives it, the claims covered, and when it becomes effective. Review the consequences of nonperformance rather than relying on an informal assurance. The wording should match the consideration actually being exchanged.
Close the loop
Keep evidence of payment, surrender, and performance. If a lawsuit is pending, have counsel handle the appropriate court papers. Update the management file so future staff do not pursue an obligation that was released or overlook one that survived. A documented resolution is more useful than a thread ending with “agreed.”
Prepare for your conversation
Sources & further reading
Shipp Law landlord representation ↗Source links checked during preparation on November 4, 2026. Statutes, lease terms, court orders, and the facts of a particular matter must be reviewed together.
