1. Non-Disparagement: Used when parties agree not to make negative statements about each other

2. Deed of Release: When the settlement requires a separate deed of release to be executed

3. Intellectual Property Rights: When the settlement involves transfer or licensing of IP rights

4. Non-Admission of Liability: When parties wish to explicitly state that settlement does not constitute admission of liability

5. Future Cooperation: When ongoing cooperation between parties is required post-settlement

6. Tax Treatment: When settlement involves significant payments requiring tax consideration

7. Insurance and Indemnity: When insurance claims or indemnification are part of the settlement

8. Third Party Rights: When settlement affects rights of parties not directly involved in the mediation

1. Schedule 1 - Payment Schedule: Detailed breakdown of payment amounts, dates, and conditions

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

3. Schedule 3 - Implementation Timeline: Detailed timeline for implementing settlement terms

4. Schedule 4 - Required Documents: List of documents to be executed or exchanged as part of settlement

5. Appendix A - Defined Terms: Extended definitions if too lengthy for main agreement

6. Appendix B - Form of Release: Template for any required release documents

7. Appendix C - Asset Schedule: If settlement involves transfer of assets, detailed list and description