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1. Parties: Identification of all parties to the agreement, including full legal names, addresses, and registration details if companies
2. Background: Recitals describing the dispute or claims being settled, relevant history, and parties' intention to settle
3. Definitions: Key terms used throughout the agreement, including 'Claims', 'Effective Date', and specific terms relevant to the dispute
4. Settlement Sum: Details of the settlement amount, payment terms, method, and timing of payments
5. Release of Claims: Comprehensive release language specifying which claims are being released, in compliance with UAE Civil Code requirements
6. Confidentiality: Obligations regarding confidentiality of the settlement terms and underlying dispute
7. Non-Admission: Statement that the settlement does not constitute admission of liability by any party
8. Governing Law and Jurisdiction: Specification of UAE law as governing law and jurisdiction of UAE courts
9. Entire Agreement: Confirmation that this document represents the entire agreement between parties regarding the settled matters
10. Execution: Signature requirements and execution formalities in accordance with UAE law
1. Non-Disparagement: Used when parties wish to prevent negative statements about each other after settlement
2. Return of Property: Include when settlement involves return of documents, equipment, or other property
3. Tax Implications: Required when settlement has significant tax consequences that need to be addressed
4. Future Cooperation: Used when parties need to specify ongoing obligations or cooperation after settlement
5. Insurance Claims: Include when settlement involves insurance claims or insurers' rights
6. Representations and Warranties: Added when specific assurances from parties are required regarding their authority or claims
7. Dispute Resolution: Optional alternative dispute resolution mechanisms for future disputes about the settlement
8. Third Party Rights: Include when settlement affects rights of third parties not direct parties to the agreement
1. Schedule 1 - Payment Schedule: Detailed breakdown of payment installments, dates, and methods if payment is not made in one lump sum
2. Schedule 2 - Released Claims: Comprehensive list of specific claims being released under the agreement
3. Schedule 3 - Related Proceedings: List of all legal proceedings to be discontinued as part of the settlement
4. Schedule 4 - Required Actions: List of specific actions parties must take to implement the settlement
5. Appendix A - Related Documents: Copies of relevant documents referenced in the settlement agreement
6. Appendix B - Form of Release: Template of any additional release documents required to be executed
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