Settlement Offer Memorandum. The Settlement Offer will be sent to Defendants before the final Settlement Hearing (prior to trial). It should set out our theory of the case, the injuries suffered, what we see as the liability of Defendants and the damages we are requesting. Much of this can be copied from the complaint, and then updated with the subsequent information we have learned throughout the case. Offer to Settle for $175,000 and, if they settle, we will dismiss the case with prejudice