1. Plan for the what-if contingencies. You might not need to address every remotely-conceivable possibility, though.
2. State who will do what, when (and how?), to achieve the things that the parties want to happen. But don’t assume you have to spell out every little step.
3. Provide for the care and feeding of the parties’ relationship.
4. It’s no sin to explain things: Later readers might not know what was in the negotiators’ minds —and a judge or juror certainly won’t.
5. Use short, simple words and sentences and paragraphs, a.k.a. plain English.