1. All parties shall file and serve on all other parties a Mediation Brief no later than seven (7) days before the Mediation.

2. The Mediation Brief shall be not more than six (6) pages single spaced consisting of:​

    2.1. Not more than two (2) pages of material facts,​

    2.2. Not more than two (2) pages of dispositive law, cases and statutes,

    2.3. Not more than one (1) page of a summary of material historical procedural and substantive events in the litigation,​

    2.4. Not more than one (1) page of a summary of (i) existing attorneys’ fees and costs paid to date plus anticipated future        attorneys’ fees and costs through all post-trial motions and (ii) the dates, amounts, and terms of all prior settlement proposals by the parties, and

    2.5. The four (4) pages allocated for material facts and dispositive law in parts 2.1 and 2.2 above may be reallocated by the parties in their discretion, e.g. three (3) pages of material facts, (1) page of dispositive law, etc.

3. Concurrently with the filing of the Mediation Briefs, the parties shall submit to the Mediator a not greater than one (1) page list of essential needs, if any, unrelated to a settlement payment, that are material and necessary for a mediated settlement. 

4. If a party wants to communicate sensitive confidential information privately to the Mediator, that party may file a not greater than two (2) page single spaced confidential Mediation Brief supplement with the Mediator without serving the other and/or adverse parties.