Alternative Dispute Resolution Scheme: Template

Template LetterDear Sir or Madam:

We are writing with reference to the matters that are presently in dispute between us (insert details of the dispute). We are mindful of the Civil Procedure Rules and are seeking a mutually satisfactory settlement of this issue. As a result, we are informing you of our willingness to cooperate in voluntary, non-binding and confidential mediation.

In order to facilitate this, we hereby propose that a neutral mediator from (insert name of organisation/trade association/other) should be appointed by consent to assist us with this matter. We are seeking this resolution in order to avoid resorting to litigation or other disposal of the case. We confirm that we agree that the Mediation shall be entirely confidential and conducted on a without prejudice basis. Nothing disclosed within the mediation shall be admitted in evidence in any future court or other proceedings.

In good faith we therefore invite you to participate in mediation. If you are not willing to attempt this form of dispute resolution, we hereby notify you of our right to produce this letter for the consideration of the court, should the issue of costs become necessary (CPR 44.4-5).

We therefore await your response to our invitation. Please note that we would respectfully request a response no later than (insert time) on (insert date) of (insert year.)

Yours faithfully

(your name)