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- Maximizing Damages in Small Personal Injury Cases - 2014
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- Settlement Negotiations
Form Requesting Early Neutral Evaluation in Addition to Mediation
The undersigned counsel, on behalf of the plaintiff/claimant hereby requests that the process of early neutral evaluation be conducted in addition to mediation in the above matter. The request is made that the settlement positions of the parties and the policy limits not be disclosed until the mediator has indicated a value range of this particular case. In addition to the insurance carrier’s willingness to allow this process, the following is agreed upon:
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That the value placed by the mediator is absolutely non-binding and cannot be used or disclosed to any judge, jury, arbitrator, or other fact finder.
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Such value indicated by the mediator may be disclosed to the parties either separately or together as determined by the insurance carrier/defendant.
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That the parties may disclose weaknesses, problems, pitfalls, liability issues, and any other issue that may...
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- Settlement Negotiations
- Sample: Response in an Automobile Case with Some Liability Question
- Stipulated Agreement for Relief from Automatic Stay
- Memorandum in support of motion for approval of agreement for relief from automatic stay
- Sample: Written Response in an Automobile Case with Clear Liability
- How to Minimize the Impact of Independent Medical Examinations
- How to Minimize the Impact of Independent Medical Examinations
- Sample: Response in a Premises Liability Case
- How to Minimize the Impact of Independent Medical Examinations
- Sample Letter: To Insurance Carrier Regarding Five and Ten- Year Medical Records Request
- Sample: Demand Letter in a Small Personal Injury Case
- Order Modifying Automatic Stay
- Sample: Written Response in Automobile Case with Questionable Damages
- Motion for Approval of Agreement for Relief from Automatic Stay with supporting Memorandum of Law
- Letter to Carrier Accepting Policy Limits in Contemplation of Bad Faith Claim for Failure to Settle a Claim Within Policy Limits
- Sample Letter to Insurance Carrier Regarding First Party Bad Faith
- Special Needs Trust (Supplemental Care Trust)
- Motion for Relief and Reinstatement Sanctions Attorney Fees
- Checklist for Requesting Early Neutral Evaluation in Addition to Mediation
- Form Requesting Early Neutral Evaluation in Addition to Mediation
- Authorization/Limited Power of Attorney
- Form for Use With Focus Groups
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