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1. Parties: Identification of all parties to the agreement, including full legal names, addresses, and registration details for companies
2. Background: Description of the dispute or liability situation, including relevant dates, circumstances, and any previous attempts at resolution
3. Definitions: Definitions of key terms used throughout the agreement
4. Settlement Amount: Clear statement of the settlement sum and any non-monetary consideration
5. Payment Terms: Details of how and when the settlement amount will be paid, including payment method and schedule
6. Release Provisions: Mutual or unilateral release of claims related to the settled matter
7. Confidentiality: Obligations regarding confidentiality of the settlement terms and related information
8. Representations and Warranties: Statements of fact and assurances from each party
9. Further Assurance: Commitment to execute additional documents or take further actions if necessary
10. Governing Law and Jurisdiction: Specification of UAE law as governing law and designation of competent courts
11. Entire Agreement: Confirmation that this agreement represents the complete understanding between parties
12. Execution: Signature blocks and execution requirements
1. Non-Admission of Liability: Statement that the settlement does not constitute admission of liability (used when explicitly requested by settling party)
2. Tax Implications: Addressing responsibility for any tax consequences of the settlement (relevant for large settlements or cross-border matters)
3. Insurance Provisions: Details of any insurance aspects of the settlement (when insurance companies are involved)
4. Third Party Rights: Provisions regarding rights of third parties affected by the settlement (when third parties have interests in the settled matter)
5. Severability: Provision for survival of agreement if parts are found invalid (used in complex settlements)
6. Amendment Procedure: Process for making changes to the agreement (for complex settlements that might need future adjustment)
7. Force Majeure: Provisions for unforeseen circumstances affecting settlement performance (relevant for settlements with ongoing obligations)
1. Schedule 1 - Payment Schedule: Detailed breakdown of payment installments and dates if settlement involves multiple payments
2. Schedule 2 - Released Claims: Comprehensive list of all claims being settled and released
3. Schedule 3 - Supporting Documents: List of relevant documents evidencing the original dispute or liability
4. Schedule 4 - Party Representatives: Details of authorized representatives and their authority to settle
5. Appendix A - Original Dispute Documents: Copies of key documents relating to the original dispute
6. Appendix B - Settlement Calculations: Detailed calculations showing how settlement amount was determined
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