Mediation Position Statement Template

Parties: [Claimant] and [Defendant / Insurer]
Date of loss: [Date]
Claim number: [Number]

Liability summary:
[Explain the facts and evidence supporting liability. Identify any disputed fault issue.]

Causation summary:
[Connect the incident to the treatment chronology. Address prior conditions honestly.]

Damages:
Medical expenses: $[amount]
Wage loss: $[amount]
Future care: $[amount]
Property loss: $[amount]
Non-economic impact: [summary]
Liens/subrogation: [summary]

Resolution position:
[Opening number, bracket, or range]. This statement is for settlement discussion and is not legal advice.