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Delaware Mediation Conference Statement

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IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

COUNTY: NEW CASTLE KENT SUSSEX

)
Plaintiff (s), )
) C.A. No.:
V. )
)
)
Defendant (s). )

MEDIATOR'S REPORT

A mediation conference was held in the above-captioned case on

This mediator reports that:

1. All parties present.

The following party(ies) present:

2. Meaningful mediation sessions take place.

3. As a result of mediation, this case is:

SETTLED**

SCHEDULED WITH ME FOR ADDITIONAL MEDIATION

AT IMPASSE AND READY FOR SCHEDULING ORDER

READY FOR TRIAL ($150.00 TRIAL FEE IS NOW DUE)

READY FOR ARBITRATION

OTHER (PLEASE SPECIFY)

** NOTICE TO ALL PARTIES: If a Stipulation of Dismissal is not filed within sixty (60) days of the date, the case will be referred to the assigned Judge for dismissal.

Dated :

Mediator's Signature

Mediator's Name (Please Print)

cc: Counsel & All Parties Revised 8.21.03

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What a Delaware Mediation Conference Statement Is

A Delaware Mediation Conference Statement is a concise written summary prepared by a party or counsel ahead of a court-ordered or private mediation in Delaware. It typically outlines the case caption, procedural posture, disputed issues, key facts, legal theories, witness and exhibit lists, settlement history, and the party’s position or proposed resolution. Courts and mediators use the statement to focus settlement discussions and allocate time at the conference. Parties usually exchange these statements under a confidentiality protocol specified by the mediator or scheduling order.

Why preparing a clear statement matters

A well-crafted mediation statement clarifies litigation posture, assists the mediator in prioritizing issues, and signals readiness to negotiate while preserving positions for counsel and the court.

Why preparing a clear statement matters

Who prepares and reviews these statements

Both parties and the mediator rely on the statement to streamline the conference and reduce repetitive briefing during settlement discussions.

  • Plaintiff or claimant counsel — summarizes allegations, damages, and witness/exhibit plan.
  • Defense counsel or respondent — outlines defenses, counterclaims, and evidentiary highlights.
  • Mediator / court staff — uses the statement to set the agenda and manage time.

Step-by-step: preparing the statement

Follow these sequential tasks to produce a complete, court-ready mediation statement.

  • 01
    Draft Core Summary: Summarize key facts and legal positions in one or two pages.
  • 02
    List Issues: Bulletize contested issues to focus mediation time.
  • 03
    Compile Exhibits: Index and paginate exhibits; note admissibility if known.
  • 04
    Exchange & File: Provide opposing counsel and mediator required copies within scheduling deadlines.

Typical submission and routing process

Mediation statements follow a predictable flow from preparation through delivery to the mediator and opposing counsel.

  • Prepare Document: Finalize statement and attach exhibits in PDF format.
  • Serve Opposing Party: Email or e-file per scheduling order; confirm receipt.
  • Deliver to Mediator: Send confidential copy to mediator via secure channel.
  • Retain Proof: Keep transmission receipts and a signed copy for the file.

Essential sections to include in a professional statement

A complete mediation conference statement combines procedural context, factual summary, legal claims, evidentiary plan, settlement posture, and logistical details for the conference.

Case Caption

Full court name and docket number at the top so the mediator and court staff immediately identify the file; include counsel names and contact details for day-of communication.

Procedural Posture

Briefly state the stage of litigation (motions pending, discovery status, trial date) to help the mediator prioritize settlement issues and understand scheduling constraints.

Factual Summary

Concise chronology of material facts, focusing on disputed facts and key supporting documents; cite exhibit numbers and dates for quick reference during discussion.

Legal Theories

List controlling claims or defenses with succinct citations if helpful; avoid extended legal briefing but note any dispositive issues that could inform settlement value.

Exhibits & Witnesses

Provide an indexed exhibit list and identify witnesses expected to be referenced; note any foundational objections or authentication issues known in advance.

Settlement Position

State baseline and realistic range, any non-monetary priorities, and confidentiality or reservation-of-rights language to guide negotiations without disclosing privileged strategy.

Configuring a simple digital workflow for the statement

Map the typical digital steps to control preparation, authentication, and secure delivery.

Upload Document Upload final PDF with exhibits attached in the order referenced
Add Recipients Enter mediator and opposing counsel emails with role (recipient/viewer)
Set Authentication Choose email or SMS code authentication per mediator requirements
Add Confidentiality Note Attach mediator’s confidentiality protocol or protective order
Deliver & Archive Send to recipients and retain a dated copy for the case file

Technical considerations for secure e-submission

Verify any platform security certifications or business associate agreements before transmitting sensitive or health-related information to meet privacy obligations.

  • File Formats: PDF preferred for courts and mediators
  • Authentication: Email or SMS code commonly accepted
  • Integrations: Works with case management and cloud storage

Typical timelines and deadlines to track

Timing for exchanges and filings varies by court order, but common pre-mediation deadlines help ensure an orderly conference.

Pre-conference exchange:

Often 7–14 days before mediation for statements and exhibits

Exhibit delivery deadline:

Commonly 3–7 days before the mediation session

Mediator submissions:

Some mediators request confidential position letters 3 days prior

Day-of protocol:

Confirm attendance, estimated session length, and breakout plan

Post-mediation filings:

File settlement documents or proposed orders within agreed timeframe

Key milestones leading to the mediation conference

Use this milestone sequence to coordinate preparation and exchanges in advance of the conference.

01

Draft Statement

Complete initial draft and circulate internally for edits.

02

Finalize Exhibits

Index and paginate exhibits; resolve any authenticity disputes.

03

Exchange with Opposing Party

Provide copies to opposing counsel per scheduling order.

04

Submit to Mediator

Send confidential copy and confirm receipt and instructions.

Common preparation pitfalls to avoid

  • Late exchanges of exhibits that prevent meaningful review by the mediator and opposing counsel, creating inefficient conference time.
  • Overly broad statements that mix legal briefing with mediation posture, which can confuse the mediator and obscure settlement levers.
  • Inconsistent dates, exhibit numbers, or witness listings between the statement and attachments, complicating verification and reference during the session.
  • Failing to follow the mediator’s confidentiality protocol or the court’s scheduling order, risking refusal to accept submissions.

Security and privacy checklist

Encryption: TLS 1.2/1.3 in transit
Data at rest: AES-256 encryption
Access control: Role-based permissions
Audit trail: Timestamped signing logs
HIPAA: BAA required for PHI
Standards: SOC 2 Type II, ISO 27001

Risks and consequences of deficient statements

Missed deadlines: Court or mediator sanctions possible
Incomplete disclosure: Adverse credibility or procedural disadvantage
Incorrect docketing: Document misrouted or rejected
Unauthorized disclosure: Confidentiality breaches risk sanctions
Improper authentication: E-signatures challenged for validity
Inconsistent exhibits: Evidentiary objections and delays

Practical examples of how parties use the statement

Two short examples illustrate common uses and outcomes when the statement is prepared correctly.

Commercial Lease Dispute

A landlord summarizes damages and rent history to show exposure

  • Parties exchange rent ledgers and inspection reports
  • By focusing on the primary damages and attaching key exhibits, the mediator narrowed settlement proposals and facilitated a partial resolution before the full session.

Software Contract Dispute

A vendor outlines breach claims and deliverables timeline to establish remedy priorities

  • Parties submit technical exhibits and timelines
  • Clear issue framing and a short exhibit index allowed the mediator to propose realistic tradeoffs that preserved long-term customer relations while resolving immediate payment disputes.

Comparing e-signature pricing and core features for mediation filings

Pricing and core capabilities vary; signNow is listed first for comparison. Confirm vendor plans and features before procurement.

signNow DocuSign Adobe Sign PandaDoc HelloSign
Starting Price $8/user/mo $15/user/mo $14/user/mo $19/user/mo $15/user/mo
Free Trial 7-day free trial Varies by plan Varies by plan Varies by plan Varies by plan
Bulk Send Yes (Business Premium) Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No

Frequently asked questions about mediation statements and e-submission

Answers to common questions about execution, electronic submission, confidentiality, and post‑mediation handling.


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