Below is my suggested format for an agreed mediation plan to be filed in those King County cases slected for the Early Mediation Pilot Program.
A Word version is available here: Agreed Mediation Plan
SUPERIOR COURT OF WASHINGTON FOR KING COUNTY
AGREED MEDIATION PLAN
COME NOW the parties to this case, by and through their attorneys of record, and stipulate and agree to the below-outlined early mediation plan as follows:
1. Counsel for the parties have met and conferred regarding mediation.
2. The parties’ meet and confer was conducted [by telephone conference call] [by in-person meeting] on [date].
3. The parties have agreed to retain [name of mediator] as the mediator.
4. The mediation is scheduled for [date and time – the sooner the better, but at least 168 days prior to the scheduled trial date] at [location].
5. The parties [anticipate] [have agreed] that [describe the type(s) of discovery, if any (e.g., “lay down” of reliance documents, interrogatories, requests for production, depositions, requests for admission) and, if appropriate, the staging or sequence of same and the number of requests, interrogatories, depositions, etc., that may be utilized prior to mediation].
6. The [principal] issues to be addressed at the mediation involve [describe].
7. The parties will submit written mediation materials to the mediator, with a copy of same to opposing counsel, no later than close of business on [date]. [In addition to providing the mediator and opposing counsel with a copy of their main mediation materials, the parties may submit a private letter to the mediator, which will not be provided to opposing counsel.]
Attorneys for Plaintiff(s):
Attorneys for Defendant(s):