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1. Parties: Detailed identification of all parties involved in the settlement, including their full legal names, addresses, and registration details if corporate entities
2. Background: Recitals explaining the context of the original dispute, any prior proceedings, and the parties' intention to settle
3. Definitions: Definitions of key terms used throughout the agreement, including references to the original dispute and settlement terms
4. Settlement Terms: Detailed description of the agreed settlement, including payment amounts, payment schedule, and any other obligations
5. Release and Waiver: Mutual release of claims and waiver of rights related to the original dispute
6. Payment Terms: Specific details of payment arrangements, including method, currency, and timing
7. Confidentiality: Obligations regarding confidentiality of the settlement terms and related discussions
8. Non-Disparagement: Mutual agreements not to make negative statements about other parties
9. Governing Law and Jurisdiction: Specification of UAE law as governing law and relevant courts' jurisdiction
10. Entire Agreement: Confirmation that this agreement represents the entire understanding between parties
11. Execution: Signing requirements and effective date of the agreement
1. Non-Admission of Liability: Statement that the settlement does not constitute admission of liability (used when specifically requested by settling party)
2. Tax Implications: Addresses tax responsibilities for settlement payments (used when settlement involves significant monetary compensation)
3. Future Cooperation: Terms for ongoing business relationship if parties plan to continue working together
4. Insurance and Indemnification: Details about insurance coverage and indemnification obligations (used when relevant to the original dispute)
5. Publicity and Announcements: Guidelines for public statements about the settlement (used in high-profile cases)
6. Return of Documents: Provisions for returning confidential documents (used when sensitive information was exchanged)
7. Dispute Resolution: Alternative dispute resolution mechanisms for settlement-related disputes (used in complex settlements)
1. Schedule 1 - Payment Schedule: Detailed breakdown of payment installments, dates, and amounts
2. Schedule 2 - Released Claims: Comprehensive list of all claims being settled and released
3. Schedule 3 - Settlement Assets: Details of any assets or properties involved in the settlement
4. Schedule 4 - Required Actions: List of specific actions parties must take to fulfill settlement terms
5. Appendix A - Original Dispute Documents: Reference copies of key documents from the original dispute
6. Appendix B - Form of Release: Template for any additional release documents required
7. Appendix C - Communication Protocol: Procedures for communications between parties post-settlement
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