Type and amount of documentation

• Papers must be delivered to CEDR Solve at least seven and preferably 14 days before the mediation
• Length should vary from four to ten pages for straightforward matters to 20-25 pages in a more complex matter
• Papers should aim to educate the mediator and persuade the other party to negotiate
• Papers should not be a trial advocacy brief nor bundles of pleadings, witness statements or footnotes supporting a brief submission
• Additional core documentation can be given if it adds to the mediation submission rather than replaces it

A submission should cover:

• factual summary
• short statement outlining type of work/business of your party
• chronology of events if relevant
• dramatis personae if relevant
• outline the legal issues
• outline the factual issues
• identify common ground and difference
• chronology of negotiation history up to last offer
• court/arbitration timetable should dispute remain unresolved
• glossary of technical terms if relevant
• schedule of key documents, indexed and paginated

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