Provide the Mediator with an Effective Mediation Statement.

Many mediation statements lack information essential to the Mediator’s understanding of the case. An effective statement will be submitted on time and will include: 1) a brief statement of facts, issues and positions; 2) attached critical pleadings, e.g., complaint, answer and affirmative defenses, pending motions for summary judgment, important orders entered by the court; 3) attached highlighted copies of critical documents and of controlling statutes and cases; 4) current status of pre-mediation settlement negotiations; 5) identity and relationship to case of parties who will attend the mediation; 6) identity of non-parties whose input may be necessary to reach a settlement; 7) any obstacles to settlement.


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Download Chapter By Francis L. Carter

Bankruptcy Mediation is a treatise published by the American Bankruptcy Institute