Draft Mediation Statement
Forward case materials (pleadings, discovery, notes). Specify jurisdiction and mediation context. Receive mediator-optimized statement.
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Subject
FWD: Mediation statement materials - Clearwater v. Meridian dispute
---------- Forwarded message ----------
From: Sarah Chen <s.chen@meridiantech.com>
To: David Clearwater <dclearwater@clearwaterservices.com>
Subject: RE: Outstanding invoices and project termination
David,
I've reviewed your termination notice dated March 15. While we disagree with your characterization of our performance, Meridian Tech remains committed to resolving this matter professionally.
Our records show:
- Project commenced January 10, 2024
- Initial deliverables completed by February deadline
- Your team requested scope changes on February 28
- We provided revised timeline March 5
- You terminated without cause March 15
Outstanding invoices total $847,000 for completed work. Additionally, we incurred $203,000 in non-recoverable costs preparing for phases 2-3.
We propose mediation to resolve both the payment dispute and your claims regarding delayed delivery. Meridian values our 8-year relationship with Clearwater and hopes to find mutually acceptable resolution.
Please let me know your availability for ADR proceedings.
Sarah Chen
General Counsel, Meridian Tech Solutions
[Attached: Invoice_Summary_Q1_2024.pdf, Project_Timeline_Original.pdf, Scope_Change_Requests.pdf, Termination_Notice_3-15-24.pdf]
From: Sarah Chen <s.chen@meridiantech.com>
To: David Clearwater <dclearwater@clearwaterservices.com>
Subject: RE: Outstanding invoices and project termination
David,
I've reviewed your termination notice dated March 15. While we disagree with your characterization of our performance, Meridian Tech remains committed to resolving this matter professionally.
Our records show:
- Project commenced January 10, 2024
- Initial deliverables completed by February deadline
- Your team requested scope changes on February 28
- We provided revised timeline March 5
- You terminated without cause March 15
Outstanding invoices total $847,000 for completed work. Additionally, we incurred $203,000 in non-recoverable costs preparing for phases 2-3.
We propose mediation to resolve both the payment dispute and your claims regarding delayed delivery. Meridian values our 8-year relationship with Clearwater and hopes to find mutually acceptable resolution.
Please let me know your availability for ADR proceedings.
Sarah Chen
General Counsel, Meridian Tech Solutions
[Attached: Invoice_Summary_Q1_2024.pdf, Project_Timeline_Original.pdf, Scope_Change_Requests.pdf, Termination_Notice_3-15-24.pdf]
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