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1. Confidentiality: Terms of confidentiality when parties wish to keep the settlement private

2. Ongoing Medical Treatment: Provisions for future medical expenses where ongoing treatment is required

3. Multiple Defendants: Additional provisions when settlement involves multiple defendants and apportionment of liability

4. Social Welfare: Provisions regarding repayment of social welfare benefits received

5. Insurance: Specific provisions regarding insurance company involvement and requirements

6. Non-Admission of Liability: Express statement that settlement does not constitute admission of liability

7. Future Claims: Provisions for potential future claims in cases involving minors or ongoing medical issues

8. Indemnities: Additional indemnities beyond standard releases when specific risks need to be addressed

1. Schedule 1 - Medical Reports: List and copies of all medical reports relied upon for the settlement

2. Schedule 2 - Special Damages: Detailed breakdown of special damages claimed and agreed

3. Schedule 3 - Accident Report: Official accident reports, police reports, or workplace incident reports

4. Schedule 4 - Vouchers and Receipts: Documentation supporting expenses claimed

5. Schedule 5 - Court Orders: Copies of any relevant court orders or PIAB assessments

6. Appendix A - Photographs: Relevant photographs of injuries, accident scene, or damaged property

7. Appendix B - Payment Schedule: Detailed payment schedule if settlement is to be paid in installments