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Briefs of no more than fourteen (14) pages in length, exclusive of necessary exhibits which are pertinent but not easily summarized in the brief itself should be submitted by each party prior to the mediation or arbitration. 

Necessary exhibits may be attached and should include special damage documentation, helpful color photocopies of photographs, pertinent contracts and relevant expert reports. Such exhibits should not include extensive medical records or excerpts thereof, extensive deposition testimony or excerpts thereof or other voluminous records or documents. Such items may just be brought to the hearing.

Briefs for mediation or arbitration should be exchanged by the parties and should cover the following five points:

 1. Parties/Counsel.

 2. An objective general statement of case.

 3. Your contentions re: liability.

 4. Nature and extent of claimed damages and your contentions re: damages. 

 5.  For Mediation only, settlement discussion history - Last settlement demand/Last settlement offer. For Arbitration only, what award or result you hope to achieve.

You may also prepare a confidential supplemental brief of no more than seven (7) pages for the mediator only in a mediation. Please mark the first page as such and also briefly address the following seven points in addition to the five points above:

 1. What facts or issues do you think the other side is avoiding? 

 2. Factual and legal strengths of each adversary's case.

 3. Factual and legal weakness of your case.

 4. What do you think the other party views as a fair outcome in this case?

 5. What do you see as the principal barriers to settlement?

 6. What you hope to achieve at the mediation? 

 7. What other information do you want the mediator to know to better understand the dispute from your client's perspective?

In order to ensure that your briefs are in compliance and receive the full attention they deserve, all briefs should be received by TLC Resolutions at least seven (7) calendar days before the hearing. Thank you for your cooperation. Briefs that comply with these guidelines will not require any supplemental charges for review.







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