Three turns and a check. Keep this open next to your chat: each step is the thing to paste next, with what you typed already carried across. Nothing is sent from here, and nothing on this page is a transcript. The conversation stays where you are having it.
Everything agreed, including anything agreed orally and not yet written down.
Every entity and individual on both sides, and the claims pleaded and unpleaded.
The law that governs the agreement and the court the case is pending in.
Your side, since the release is not symmetrical even when it is mutual.
Deadlines, approvals, liens, and anything that has to happen before signature.
Watch for, the whole way through
Whether unknown claims can be waived, whether particular statutory claims are waivable at all, and whether confidentiality is enforceable in certain claim types are all governed by the applicable law and vary sharply. Confirm each before signing.
Liens and reimbursement rights, including government payer claims, survive an agreement between the parties. A release that ignores them does not protect the payer.
A term agreed orally at mediation and not written down is the most common source of post-settlement disputes. Write down everything, including what was said about timing.
Tax reporting and allocation have real consequences for both sides and are frequently left to the end. Raise them before signature, not after the money moves.
Do not paste confidential settlement terms unless your firm's AI policy, the engagement terms, and any mediation confidentiality rules permit it.