The Mediator's Proposal - A Useful Settlement Tool
A mediator’s proposal is best described as settlement terms presented by the mediator to parties that have reached an impasse in their settlement negotiations.
Generally speaking, the proposal should not invite a counter-offer or new terms. It is important that the parties either accept or reject the mediator’s proposal as written within the time specified.
Most often, such proposals are “double blind”. The following language taken from a mediator’s proposal illustrate

