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MEDIATION BRIEF

Suggested format for a mediation brief

[Attorney Letterhead] (including fax no.)	Case No.
Plaintiff(s), v. Defendant(s), __________________________/	MEDIATION BRIEF OF (PLAINTIFF/DEFENDANT, ETC), (PARTY'S NAME)

1. PARTIES AND COUNSEL
   1. Identify separately each Plaintiff and the respective attorney of record
   2. (Plaintiffs) Also identify each outstanding lien claimant and the total amount claimed by each
   3. Identify separately each Defendant and the respective attorney of record
   4. (Defendants) Also identify each insurance carrier and the name of the assigned adjuster or corporate representative

2. CASE STATEMENT
   Provide a short statement of the facts of this case:

3. PLAINTIFF
   Explain your position on this case
   List all economic damages claimed in this case
   List all non-economic damages claimed in this case
   Specify attorney fees, if any, that may be awarded to you

4. DEFENDANT
   Explain your position on this case
   Specify attorney fees, if any, that may be awarded to you

5. LEGAL ISSUES
   Identify major disputed legal issues

6. FACTUAL ISSUES
   Identify major disputed factual issues

7. OFFERS
   Specify all 998 offers made
   What is the last best offer to settle made by each party?
   Plaintiff(s)
   Defendant(s)
   Other(s)

8. SETTLEMENT EFFORTS
   State what efforts have been made to settle

9. ATTACHMENTS
   Provide additional information or attachments, if any, which will aid the mediator (such as excerpts from medical or police reports, photographs, compilations of damages, contracts, arbitrator decision, etc.)