CONSIDERING that the defendant has asserted certain claims against the applicant; CONSIDERING that the parties to the dispute have agreed to settle and settle by mutual agreement the rights and defences in the dispute; and such confidential settlement agreement (“Settlement Agreement”) shall, from that day of [month], [year] be between [applicants] (“applicants”) and [defendant] (a “party” and, jointly, the “parties”), the applicants waive without appeal and forever all rights that may arise from the law with respect to the ongoing dispute and the declassification above. . . .