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1. Non-admission of Liability: Statement that settlement does not constitute admission of liability - used when specifically requested by defendant

2. Tax Implications: Provisions addressing tax treatment of settlement payments - needed when settlement involves significant monetary compensation

3. Continuing Obligations: Ongoing duties of parties post-settlement - used when settlement requires future performance

4. Third Party Rights: Provisions regarding rights of third parties under the settlement - needed when settlement affects third party interests

5. Insurance and Indemnification: Insurance-related provisions - relevant when insurance companies are involved

6. Publicity and Announcements: Terms regarding public statements about settlement - used in high-profile cases

7. Dispute Resolution: Process for resolving disputes about settlement interpretation - used in complex settlements

1. Schedule 1: Payment Terms: Detailed breakdown of settlement payments, installment schedules, and payment methods

2. Schedule 2: Released Claims: Comprehensive list of claims being settled and released

3. Schedule 3: Required Actions: Detailed list of specific actions parties must take to implement settlement

4. Schedule 4: Timeline: Detailed timeline for implementation of settlement terms

5. Appendix A: Related Court Orders: Copies of relevant previous court orders or judgments

6. Appendix B: Supporting Documents: Key documents referenced in the settlement

7. Appendix C: Form of Release: Standard form of release to be executed by parties

8. Appendix D: Consent Order: Draft consent order for court's approval