1. Concurrently with the scheduling of the Mediation, LMS will submit to counsel for the parties templates for the LMS Deal Point Agreement [DPA] and LMS Settlement Agreement and Mutual General Release [SAMGR].

2. The parties are required to:​

    2.1. Meet and confer and reach agreement on which template they prefer to use for the Mediation of this matter, the DPA or the SAMGR [Designated Template].

    2.2. Negotiate, modify, and/or supplement the Designated Template. 

    2.3. File with the Mediator concurrently with the Mediation Briefs the final execution version of the Designated Template they have selected, leaving blank only the (i) amount of the settlement payment and by whom it will be paid and (ii) other essential terms in paragraph 3 of the SAMGR and/or paragraph 4 of the DPA, for which they have not reached agreement.