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KPN Q33: If you have any particular practices or preferences in regard to submissions before a mediation, please describe them.

KPN A33: I issue a mediation order which asks each side to submit a memorandum (to me alone) of no more than four pages which addresses certain questions: the main issues in the case, the strengths and weaknesses of the respective parties' positions, the history of settlement negotiations, and the settlement that the party is seeking and/or would be satisfied to enter. The memorandum is due approximately five days before the mediation.

Related Topics:
* Neiman, Kenneth P.




United States District Court for the District of Massachusetts

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