As I wrote back to you in my email, the problem was with the name of the Actions Subform. In the database window it is, indeed, 'Actions Subform', however on the Case Subform, it is treated as nothing more than 'Actions'. The corrected code is:
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Forms![MainForm]![Case Subform].SetFocus
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Forms![MainForm]![Case Subform].Form![Settlement Amount].SetFocus
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Forms![MainForm]![Case Subform].Form![Actions].Form![Action Date].SetFocus
Good luck on the rest of your app!
Regards,
Scott