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1. Parties: Detailed identification of all parties involved in the lawsuit and settlement, including their legal capacities and addresses
2. Background: Brief overview of the dispute, reference to the court case number, and current status of proceedings
3. Definitions: Definitions of key terms used throughout the agreement
4. Settlement Amount: Clear statement of the settlement amount and any tax implications
5. Payment Terms: Detailed payment schedule, method of payment, and consequences of default
6. Mutual Release: Comprehensive release of claims by all parties against each other
7. No Admission of Liability: Statement that the settlement does not constitute admission of liability by any party
8. Court Approval: Provisions regarding submission of settlement to court and obtaining court approval
9. Governing Law: Specification that Pakistani law governs the agreement
10. Entire Agreement: Clause stating this document represents the complete agreement between parties
11. Binding Effect: Statement that the agreement is binding on parties, their heirs, and successors
12. Execution: Details about how and when the agreement becomes effective
1. Confidentiality: Terms of confidentiality regarding the settlement terms and dispute - include when parties want to keep settlement private
2. Non-Disparagement: Prohibitions against making negative statements about other parties - useful in high-profile or sensitive cases
3. Return of Documents: Provisions for returning sensitive documents - include when confidential information was exchanged during litigation
4. Insurance Provisions: Details about insurance coverage and claims - relevant when insurance companies are involved
5. Tax Indemnification: Provisions regarding tax liability - include when settlement has significant tax implications
6. Dismissal of Proceedings: Specific procedures for dismissing the lawsuit - include when multiple court proceedings are involved
7. Future Cooperation: Requirements for future cooperation between parties - useful in complex cases requiring ongoing interaction
1. Schedule A - Payment Schedule: Detailed breakdown of payment installments, dates, and methods
2. Schedule B - List of Claims: Comprehensive list of all claims being settled
3. Schedule C - Court Proceedings: Details of all related court proceedings and case numbers
4. Appendix 1 - Original Court Documents: Copies of relevant court filings and orders
5. Appendix 2 - Evidence Documentation: List of key evidence or documents referenced in the settlement
6. Appendix 3 - Related Agreements: Copies of any related agreements or documents referenced in the settlement
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