​​The Parties, their respective Counsel and the Mediator agree to use Mediation for resolving a dispute concerning the following parties in accordance with the following terms:

PARTY:_______________________________________________________________________________, and

PARTY:  _______________________________________________________________________________

MEDIATOR:   Charles H. Pelton Attorney at Law PLLC will serve as Mediator. 

ATTORNEYS:  The parties will consult with their respective attorneys on the law, legal advice and counsel.  The mediator is serving as a neutral to help resolve the dispute and is not an advocate for any party.

CAUCUSES:  The Mediator will use private caucuses with the parties separately to better understand their positions and will not disclose confidential information to the other party unless authorized.

CONFIDENTIALITY:  The parties agree that mediation sessions are settlement negotiations and as such all private information disclosed by the parties are deemed confidential, will not be disclosed and are not subject to subpoena or admissible in trial, subject to the following exceptions:
1.    The parties may agree to partial or complete disclosure.
2.    Imminent threats or crimes where there is a legal duty to report.  
3.    Upon settlement of the dispute by agreement of the parties, settlement terms will be memorialized by an oral or written agreement and those terms and this document may be used in any relevant proceeding to enforce the terms and the Mediator may be called as a witness to confirm the terms, unless the parties agree otherwise in writing.

FEES:  Mediation services, including preparation time of not more than two hours, will be charged at the rate of $250 per hour, payable one half by each party (unless otherwise agreed).   Fees will be billed through Counsel following Mediation.

​DATED:  ______________________________________ AT(CITY)______________________________________

Party & Counsel:______________________________________________________________________________
Party & Counsel:______________________________________________________________________________