Dear Legal Counsel:

This will confirm your agreement to mediate issues related to: __________________________________________________________________.

Our first mediation session is scheduled on ___________________, at my office (_________________________________).

To prepare for the mediation, I request that each of you prepare a mediation brief, not to exceed five pages. The brief should:

∙ identify the parties involved; ∙ summarize the facts; ∙ concisely state the issues; ∙ identify the damages and set forth computations if appropriate; ∙ discuss insurance coverage questions, if any; and ∙ provide the last communicated demand and offer, if applicable. Please mail these mediation briefs to my office no later than________ and simultaneously send a copy to each other party.

Please also bring any documentation to the mediation conference that you think supports your requests or is otherwise relevant to disposition of this matter.

In order to streamline our efforts, it is important that all parties and companies who have an interest in the outcome of the dispute attend the mediation conference. If you know of any party who may not have been notified or who is not planning to attend, please contact me. It is also important that we have full authority available to settle this matter, so I ask that you make the necessary arrangements.

If you have any questions, please do not hesitate to contact me.

Sincerely,

James C. Melamed, J.D.

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