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1. Parties: Identification and details of all parties involved in the settlement, including their legal status and addresses
2. Background: Recitals explaining the context of the dispute, any existing legal proceedings, and the parties' intention to settle
3. Definitions: Definitions of key terms used throughout the agreement
4. Settlement Amount: Clear statement of the settlement sum and payment terms
5. Release and Discharge: Mutual release of claims and specific terms of discharge of liability
6. Confidentiality: Obligations regarding confidentiality of the settlement terms and dispute
7. Non-Admission: Statement that the settlement does not constitute admission of liability
8. Representations and Warranties: Basic representations about authority to enter agreement and binding nature of obligations
9. Entire Agreement: Confirmation that this document represents the complete agreement between parties
10. Governing Law and Jurisdiction: Specification of Pakistani law as governing law and relevant jurisdiction
11. Execution: Signature blocks and execution requirements
1. Payment Schedule: Detailed payment terms if settlement involves installments or multiple payments
2. Tax Implications: Include when settlement payment has specific tax considerations or requirements
3. Non-Disparagement: Additional provisions preventing parties from making negative statements about each other
4. Ongoing Obligations: Any continuing obligations or responsibilities of either party post-settlement
5. Third Party Rights: Include when settlement affects rights of parties not directly involved in the agreement
6. Insurance Provisions: Required when insurance companies are involved in the settlement
7. Return of Property/Documents: Include when physical items or documents need to be returned as part of settlement
8. Dismissal of Proceedings: Include when there are ongoing legal proceedings that need to be terminated
1. Payment Details: Schedule containing detailed payment information including bank details
2. List of Released Claims: Comprehensive list of all claims being settled and released
3. Related Proceedings: Details of any legal proceedings being terminated as part of settlement
4. Existing Agreements: List of any existing agreements affected by or relevant to the settlement
5. Form of Release: Template of any additional release documents to be executed
6. Required Notices: Forms of any notices required under the agreement
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