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SAMPLE CONFIDENTIAL MEDIATION STATEMENT
This Confidential Mediation Statement is submitted on behalf of
____________________________________ [who] [which] is a party to the
[Dispute] [Civil Action pending in the __________________________] described
below. It is understood that this Confidential Mediation Statement is for the use
of the Mediator only and has not been served on the other Mediating Party[ies].
I. Nature of the [Dispute] [Civil Action]
(Please provide a brief summary of the nature of the [Dispute] [Civil
Action].)
II. Procedural Posture of the [Dispute] [Civil Action]
(Please provide a brief summary of the procedure posture of the [Dispute]
[Civil Action] and, if a civil action, describe the status of pleading and
motion practice and of discovery.)
III. Settlement Posture of the Matter
(Please provide a brief summary of any settlement negotiations that have
taken place between the parties, and any offers made.)
IV. Concise Summary of the Facts
(Please provide a statement of the facts of the [Dispute] [Civil Action].)
V. Fact Issues
(Please set forth the important fact issues in the [Dispute] [Civil Action].)
VI. Legal Issues
(Please set forth the legal issues which will be determinative of the
[Dispute] [Civil Action].)
VII. Applicable Authority
(Please set forth applicable statutory and case authority upon which you
rely in support of the claims or defenses in this matter.)
VIII. Evaluation of the Case (optional)
(Please set forth the strengths and weaknesses of your client’s case and the
opposition case.)