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1. Parties: Identifies and defines all parties to the settlement agreement
2. Background: Outlines the context of the dispute and circumstances leading to settlement
3. Definitions and Interpretation: Defines key terms and establishes interpretation principles
4. Settlement Sum: Specifies the settlement amount and payment terms
5. Release and Discharge: Details the scope of claims being released and discharged
6. Bar to Future Actions: Prevents future legal actions related to released claims
7. Confidentiality: Establishes confidentiality obligations regarding the settlement
8. Tax Treatment: Addresses tax implications and responsibilities
9. No Admission of Liability: Confirms settlement does not constitute admission of liability
10. Entire Agreement: Confirms the agreement represents the complete understanding between parties
11. Governing Law: Specifies applicable law and jurisdiction
12. Execution: Contains signature blocks and execution requirements
1. Ongoing Obligations: Used when parties have continuing obligations post-settlement
2. Non-Disparagement: Include when parties agree not to make negative statements about each other
3. Return of Property: Required when physical or intellectual property needs to be returned
4. Deed Poll by Related Parties: Used when related entities need to be bound by the settlement
5. Mutual Releases: When both parties are releasing claims against each other
6. Warranties: Include specific representations when needed for settlement validity
7. Severability: Include when agreement needs to survive partial invalidation
8. Third Party Rights: Used when settlement affects rights of non-parties
9. Insurance and Indemnity: Include when ongoing indemnities or insurance obligations exist
1. Schedule 1 - Settlement Payment Details: Detailed breakdown of settlement payments and timing
2. Schedule 2 - Released Claims: Comprehensive list of specific claims being released
3. Schedule 3 - Related Entities: List of related parties covered by the release
4. Schedule 4 - Deed Poll: Form of deed poll for related parties to execute
5. Schedule 5 - Property Register: List of property to be returned or transferred
6. Appendix A - Agreed Public Statement: Approved form of any public announcements regarding settlement
7. Appendix B - Tax Invoice Requirements: Specified format for tax invoices related to settlement payments
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