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Guidelines for Pre-Mediation Statements

Each party is requested to submit, no later than five (5) business days before the mediation, a brief (no more than 5 pages) confidential mediation statement.  The statement may be in letter form, and may be e-mailed (mimi@satoriadr.com), faxed (888.298.0566), or mailed (Satori ADR, P.O.Box 81483, Lafayette, LA 70598).
 
The following information will help the mediator settle your case if given in a frank and candid manner. Remember that all submissions are strictly confidential:
1. The name and title, if any, of the client or authorized representative who will be attending the conference with counsel.

2. A brief statement of the key factual and legal issues involved in the litigation.

3. The main "sticking points” preventing settlement.

4. A description of any important rulings made or pending motions in the case which may have a bearing on settlement.

5. A description of the strongest and weakest points in your case, whether factual or legal.

6. The status of settlement negotiations, including the last settlement proposal made by you and to you.

7. A likely judgment range if plaintiff were to prevail, and the chance, expressed as a percentage, that plaintiff will prevail at trial.

8. A settlement proposal that you would be willing to make in order to conclude the matter and stop the expense and turmoil of litigation.

9. An estimate of costs and legal fees from the date of the conference through trial, if the case is not settled.

10.  A compensation intervenor is requested to provide the current amounts of compensation and medicals paid, an evaluation of the likelihood of future exposure and a calculation of future exposure including a description of the factors used in the calculation.

11. Key documents may be submitted if necessary for to understand the case, such as:
    a. Pretrial Stipulations or a Pretrial Order;
    b. Expert Reports;
    c. Key medical reports concerning a plaintiff’s medical condition;
    d. Brief excerpts of important deposition testimony
    e. Any other documents which counsel believe may be of benefit to the Mediator in evaluating the case.

 

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