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:

1. 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.

2. Such value indicated by the mediator may be disclosed to the parties either separately or together as determined by the insurance carrier/defendant.

3. That the parties may disclose weaknesses, problems, pitfalls, liability issues, and any other issue that may...