1. Non-Disparagement: Include when parties wish to prevent public criticism or negative statements about each other

2. Future Cooperation: Include when parties need to maintain an ongoing relationship or require future cooperation

3. Tax Implications: Include when settlement involves significant monetary compensation requiring tax consideration

4. Insurance Coverage: Include when insurance companies are involved in the settlement

5. Dispute Resolution: Include when parties want to specify how future disputes about the settlement agreement will be resolved

6. Third Party Rights: Include when the settlement affects rights of parties not directly involved in the agreement

7. Return of Property/Documents: Include when physical items or documents need to be returned as part of settlement

1. Schedule of Payments: Detailed breakdown of payment amounts, dates, and methods if settlement involves installment payments

2. Schedule of Released Claims: Comprehensive list of all claims being released through the settlement

3. Schedule of Court Proceedings: List of all court proceedings to be withdrawn, including case numbers and jurisdictions

4. Schedule of Related Documents: List of all relevant documents referenced in the settlement agreement

5. Appendix A - Form of Release: Standard form of release to be executed by the parties

6. Appendix B - Withdrawal Notice: Template for the notice of discontinuance to be filed with the court