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1. Parties: Identifies and defines all parties to the agreement, including their legal status and registered addresses
2. Background: Outlines the context of the dispute without admitting fault, referencing any existing proceedings or claims in neutral terms
3. Definitions: Defines key terms used throughout the agreement, including 'Settlement Sum', 'Effective Date', and 'Claims'
4. Settlement Terms: Details the core settlement provisions, including payment amounts, timing, and method of payment
5. Mutual Release: Comprehensive release clauses where parties release each other from all claims related to the dispute
6. No Admission of Liability: Explicit statement that the settlement does not constitute an admission of liability by any party
7. Confidentiality: Provisions regarding the confidentiality of the settlement terms and negotiations
8. Tax and Costs: Addresses responsibility for taxes and legal costs related to the settlement
9. Entire Agreement: Confirms the agreement represents the entire understanding between parties and supersedes previous agreements
10. Governing Law and Jurisdiction: Specifies Hong Kong law as governing law and Hong Kong courts' jurisdiction
11. Execution: Details how the agreement will be executed and become effective
1. Non-Disparagement: Mutual obligations not to make negative statements about other parties - include when reputation management is a concern
2. Return of Documents: Provisions for returning confidential documents - include when sensitive materials were exchanged
3. Future Cooperation: Terms for ongoing cooperation between parties - include when future interaction is necessary
4. Insurance and Indemnity: Additional protection clauses - include when dealing with potential third-party claims
5. Publicity and Announcements: Rules for public statements about the settlement - include for high-profile cases
6. Severability: Provisions for maintaining validity if parts are found unenforceable - include in complex settlements
7. Third Party Rights: Address rights of third parties under the Contracts (Rights of Third Parties) Ordinance - include when third party interests are involved
1. Schedule 1 - Payment Schedule: Detailed breakdown of payment amounts, dates, and methods if payment is to be made in installments
2. Schedule 2 - Released Claims: Comprehensive list of specific claims being settled and released
3. Schedule 3 - Related Proceedings: List of any legal proceedings to be discontinued as part of the settlement
4. Appendix A - Form of Release: Standard form for any additional releases required from related parties
5. Appendix B - Settlement Sum Calculation: Detailed calculation of settlement amounts if complex formulas are involved
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