1. Non-admission of Liability: Include when parties wish to explicitly state that the settlement does not constitute admission of liability

2. Future Dispute Resolution: Include when parties want to specify how any future disputes relating to the settlement will be resolved

3. Tax Implications: Include when settlement involves significant financial components requiring tax consideration

4. Third Party Rights: Include when settlement affects rights or obligations of parties not directly involved in the mediation

5. Regulatory Compliance: Include when settlement requires specific regulatory approvals or compliance measures

6. Implementation Timeline: Include when settlement terms require phased implementation or specific timelines

7. Non-disparagement: Include when parties wish to prevent public statements or criticism about each other

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

2. Asset Transfer Schedule: List and details of any assets to be transferred as part of the settlement

3. Compliance Requirements: Detailed list of specific actions or compliance requirements to be fulfilled by parties

4. Original Dispute Documents: Reference copies of relevant documents from the original dispute

5. Mediation Agreement: Copy of the original agreement to mediate

6. Release Documentation: Detailed forms or documents related to the mutual release of claims

7. Authorization Documents: Copies of power of attorney or board resolutions authorizing the settlement