(a)  Time for Submission.  No later than 10 calendar days before the first mediation session, or in the time established by the mediator, each party must submit directly to the mediator, a written mediation statement.  The statement may be transmitted solely to the mediator.  Whether the statement will be sent solely to the mediator, or exchanged by the parties, will be determined at the ADR L.R. 4-6 conference.

(b)  Prohibitions against Filing.  The statements must not be filed.

(c)  Content of Statement.  The statements must be concise, no more than five pages in length, and may include any information that may be useful to the mediator and, unless directed otherwise by the mediator:

          (1) identify, by name and title or status:

                   (A) the person(s) with decision-making authority, who, in addition to                          counsel, will attend the mediation as representative(s) of the party,                              and

                   (B) persons connected with a party opponent (including an insurer                              representative) whose presence might substantially improve the utility              of the mediation or the prospects for settlement;

          (2) describe briefly the substance of the suit, addressing the party’s views of     the key liability issues and damages and discussing the key evidence;

          (3) identify the discovery or motions that promise to contribute most to equipping the parties for meaningful settlement negotiations;

          (4) describe the history and current status of any settlement negotiations and    provide any other information about any interests or considerations not      described elsewhere on the statement that might be pertinent to settlement; and