1. Return/Destruction of Confidential Information: Required if confidential materials need to be returned or destroyed as part of settlement

2. Public Statements: Include when parties need to agree on public communications about the settlement

3. Third Party Rights: Include when settlement affects rights of third parties

4. Tax Implications: Include when settlement payment has significant tax considerations

5. Insurance Matters: Include when insurance companies are involved in the settlement

6. Non-Disparagement: Include when parties wish to prevent negative statements about each other

7. Injunctive Relief: Include when specific enforcement mechanisms needed beyond standard remedies

1. Original Non-Disclosure Agreement: Copy of the original NDA being settled

2. Settlement Payment Schedule: If payment is to be made in installments, details of payment dates and amounts

3. Confidential Information Index: List of specific confidential information covered by continuing obligations

4. Form of Release: Standard form for mutual release of claims

5. Agreed Public Statement: If applicable, the agreed form of any public announcement

6. Destruction Certificate: Template certificate confirming destruction of confidential information