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1. Parties: Identifies and defines all parties to the agreement, including their legal status and addresses
2. Background: Describes the context of the dispute and the parties' desire to settle
3. Definitions: Defines key terms used throughout the agreement
4. Settlement Terms: Details the core settlement provisions including any payments, actions, or obligations
5. Release and Waiver: Specifies the mutual release of claims and waiver of future rights related to the dispute
6. Representations and Warranties: States the parties' assertions about their authority and capacity to enter into the agreement
7. Implementation: Outlines the timeline and process for implementing the settlement terms
8. Governing Law and Jurisdiction: Specifies Pakistani law as governing law and defines jurisdiction for disputes
9. Entire Agreement: Confirms this document represents the complete agreement between parties
10. Execution: Signature blocks and execution formalities
1. Confidentiality: Required when parties wish to keep the settlement terms private
2. Payment Terms: Detailed payment arrangements if settlement involves financial compensation
3. Non-Admission of Liability: Statement that settlement does not constitute admission of liability
4. Tax Implications: Include when settlement involves significant financial components
5. Non-Disparagement: Prevents parties from making negative statements about each other
6. Future Dispute Resolution: Mechanism for resolving future disputes related to the settlement
7. Amendment Procedure: Process for modifying the agreement if needed
8. Severability: Ensures remainder of agreement stands if any provision is found invalid
1. Schedule A - Settlement Amount Details: Breakdown of settlement payments, installments, and payment methods
2. Schedule B - Timeline of Actions: Detailed timeline for implementing settlement terms
3. Schedule C - Released Claims: Comprehensive list of claims being settled and released
4. Schedule D - Required Documents: List of documents to be exchanged or filed as part of settlement
5. Appendix 1 - Original Dispute Documents: Key documents relating to the original dispute
6. Appendix 2 - Court References: References to any court proceedings being settled
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