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Free Claude skill · Mediation, motions, trial
Mediation Statement
A persuasive mediation statement covering liability, damages, medical evidence and settlement position.
mediation-statement/SKILL.md+2 more in the download
# Mediation Statement Drafts a mediation statement that educates the mediator on case strengths and positions the client for favorable settlement. Works for both plaintiff and defense — adjust framing accordingly. ## Prerequisites Gather before drafting: 1. **Case file** — complaint, answer, case number, mediation date, mediator name 2. **Confidentiality designation** — mediator-only or shared with opposing counsel 3. **Discovery materials** — deposition transcripts, interrogatory responses, document production 4. **Medical records** — treatment history, bills, expert reports (PI cases) 5. **Settlement history** — all demands and offers with dates 6. **Key exhibits** — photos, contracts, communications, expert reports ## Quick Start Target 5–15 pages, single-spaced, numbered exhibits. Submit 7–10 days before mediation unless mediator specifies otherwise. ## Sections ### 1. Header & Introduction Caption (Party v. Party, Case No.), mediation date, mediator name, brief cooperative opening. ### 2. Executive Summary 2–3 sentences: case type, central disputed issue, client's position. ### 3. Factual Background Present chronologically with strategic framing: - Lead with context favorable to client - Key dates, times, locations, witnesses - Reference exhibits by number - Active voice for opponent's bad acts; passive for client's unfavorable facts - **Plaintiff**: dangerous conditions, lack of warnings, defendant knowledge - **Defense**: plaintiff's conduct, obvious hazards, proper maintenance ### 4. Liability Analysis Structure element-by-element (duty → breach → causation → comparative fault): - Cite applicable statutes and case law - Show why each element favors client - Distinguish adverse authority - Preemptively rebut opponent's strongest arguments ### 5. Testimony & Discovery - Highlight favorable admissions from opposing party - Identify contradictions, credibility problems, discovery gaps - Cite specific deposition pages; attach key excerpts as exhibits selectively ### 6. Medical/Injury Analysis **PI cases** — analyze each category with client-favorable framing: | Category | Focus | |----------|-------| | Pre-incident history | Frame favorably for client | | Post-incident treatment | Records vs. claims | | Causation | Medical evidence linking injuries to incident | | Objective vs. subjective | Emphasize objective findings | | Treatment gaps | Inconsistencies, delayed treatment | | Activity level | Exaggeration or genuine limitation | **Non-PI cases** — analyze business records, contracts, communications; assess damage documentation. ### 7. Damages Analysis Break down each category and assess credibility: - Medical bills — reasonable/necessary vs. excessive/unrelated - Lost wages — documented vs. speculative - Pain and suffering — objective support vs. subjective claims - Property/economic losses — properly calculated vs. speculative - Expert opinions — reliability, basis, methodology Frame in light most favorable to client. ### 8. Expert Witness Analysis - Client's expert: qualifications, methodology, key opinions - Opponent's expert: weaknesses, potential bias - Anticipated trial impact ### 9. Trial Outlook - Jury appeal — which party benefits and why - Pending motions (MSJ, motions in limine) - Evidentiary and credibility problems opponent faces - Costs/fees exposure; appeal risks ### 10. Settlement History Chronological table of all demands and offers (date, party, amount, notes). Analyze movement and why opponent's current position is unrealistic. ### 11. Settlement Path Do **not** propose a specific number. Instead: - Identify what opponent must concede - Describe non-settlement consequences (cost, time, risk) - Address impediments to resolution - Frame which side has further to move and why ### 12. Exhibits Attach only high-impact documents: key deposition excerpts, medical chronologies, expert reports, critical communications. Limit volume — excess dilutes impact. ## Guidelines - **Tone**: Persuasive and professional — advocate hard but do not overstate disprovable facts - **Confidentiality**: Mediator-only statements can be more candid about weaknesses and realistic ranges - **Jurisdiction**: U.S. practice; adjust for state-specific mediation confidentiality rules - **Ethics**: Strategic framing is appropriate; misrepresentation of facts or law is not ## Checklist - [ ] Persuasive tone throughout - [ ] Client's position clearly articulated - [ ] Opponent's weaknesses supported with specific evidence - [ ] Settlement path provided without proposing a number - [ ] Mediator name and date correct - [ ] Exhibits numbered and referenced in text - [ ] Proofread for grammar, spelling, formatting
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