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1. Parties: Identification and details of all parties to the agreement
2. Background: Context of the dispute and circumstances leading to the settlement
3. Definitions and Interpretation: Definitions of key terms and interpretation rules for the agreement
4. Settlement Sum: Details of the settlement amount and payment terms
5. Release and Discharge: Mutual releases from claims and obligations related to the dispute
6. Bar to Future Proceedings: Covenant not to sue or bring future claims related to the settled matters
7. Confidentiality: Obligations regarding confidentiality of the settlement terms and dispute
8. Warranties and Representations: Statements of fact and assurances from each party
9. Tax and Costs: Responsibility for taxes, legal costs, and other expenses
10. Execution and Effect: When and how the agreement becomes effective
11. General Provisions: Standard boilerplate clauses including governing law, entire agreement, and severability
1. Non-Disparagement: Mutual obligations not to make negative statements about other parties - typically used in high-profile or employment-related settlements
2. Return of Property: Provisions for returning documents or property - relevant when parties have exchanged materials during their relationship
3. Ongoing Obligations: Any continuing obligations between the parties - used when settlement includes future commitments
4. Intellectual Property Rights: Provisions dealing with IP ownership and rights - relevant when dispute involves IP
5. Employment-Related Provisions: Specific clauses for employment settlements including references and post-employment restrictions
6. Third Party Rights: Provisions affecting or excluding rights of third parties - used when settlement might impact others
7. Publicity and Announcements: Guidelines for public statements about the settlement - important in high-profile cases
8. Medicare/Benefits Compliance: Provisions ensuring compliance with government benefit regulations - relevant for personal injury settlements
1. Schedule 1 - Settlement Payment Details: Detailed breakdown of settlement amounts and payment schedule
2. Schedule 2 - Claims Being Released: Comprehensive list of specific claims being settled and released
3. Schedule 3 - Deed of Release by Related Parties: Additional releases by related entities or individuals
4. Schedule 4 - Form of Announcement: Agreed form of any public statements or announcements
5. Appendix A - Related Court Documents: List of relevant court proceedings or documents being withdrawn
6. Appendix B - Compliance Documents: Any required statutory or regulatory compliance documentation
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