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Phone: 714.529.5685

                            TLC RESOLUTIONS BRIEF GUIDELINES

Parties are encouraged to limit their main briefs to twelve (12) 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.

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 bills, extensive deposition testimony or excerpts thereof or other voluminous records or documents. Such items may just be brought to the hearing.

Parties are encouraged to exchange their main briefs will all other parties and should address 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.  Settlement discussion history - Last settlement demand/Last settlement offer.


You may also prepare a confidential supplemental brief of no more than seven (7) pages for the mediator only. 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 settlement or objective do 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 five (5) calendar days before the mediation. Thank you for your cooperation. Briefs that comply with these guidelines will not require any supplemental charges for review.







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