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Settlement and Mediation Brief Template

Three sheets and four documents that take a demand apart component by component and price each one against the findings it needs.

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What you get

Pack of 7 files: 4 documents, 3 spreadsheets

Settlement and Mediation Brief Template
  • Damages ModelSpreadsheet
  • Issue ChainSpreadsheet
  • Risk-adjusted Outcome RangeSpreadsheet
  • What a Number Actually AssumesDocument
  • Client Risk MemoDocument
  • Settlement Authority NoteDocument
  • Mediation BriefDocument
RiverSettlement and Mediation Brief Template

Marbury Cold Chain v. Levanter Logistics  ·  Issue Chain

Every finding, and what disagreeing about it is worth

Illustrative figures for a fictional cold chain dispute. Marbury is the plaintiff and demands $8,400,000. Levanter is defending and paying.

The finding a fact-finder has to makeCarriesMarburyLevanterWorth
The limitation clause does not cap recovery at the freight chargeEverything45%15%$420,373
Breach: the excursion is Levanter's equipment, not Marbury's loadingEverything80%60%$120,106
Lost profits recoverable: foreseeable, and proved with reasonable certaintyLost profits40%15%$111,205
Causation: the excursion caused the spoilage found on arrivalEverything90%75%$76,431
Quantum: the fraction of the claimed lost profits a jury allowsLost profits65%35%$73,395
Cover freight is Levanter's, not the second carrier'sCover freight55%30%$28,357
Lost future customers proved at allLost customers15%3%$26,689
Common chain, the three findings everything needsmultiplied32.4%6.75%17.3% mid
The same three findings averaged insteadcheck row71.7%50.0%60.8% mid

Read the last column, not the two before it

The top row is a question about one clause, and it is worth 2.3 times the entire lost-profits fight. It is also the only finding here that no further evidence can move, because nothing factual touches a question of contract interpretation.

The bottom row is on the sheet as a check and never as an output. At the midpoint, averaging the three common findings values the claim at $5,110,000 and multiplying them values it at $1,455,300.

Both probability columns stay empty until a lawyer writes a number in. Everything to the right of them is arithmetic.

A demand is several claims wearing one number, and a percentage applied to the total prices none of them. Marbury Cold Chain wants $8,400,000 from Levanter Logistics over eight rejected refrigerated loads, and the demand letter it arrived in treats it as a single figure. The invoiced cargo loss needs liability, a limitation clause and causation. The lost profits claim needs those three plus recoverability and a quantum finding. Findings along a chain multiply rather than average, so 45, 80 and 90 percent is 32.4 percent, not 72.

At the midpoint of both sides' estimates the claim comes to $420,373, five percent of what was demanded. The $4,800,000 lost profits line is 57 percent of the demand and 27 percent of that value. The $1,200,000 claimed for lost future customers is worth $18,711, because it has a round number and no named account behind it, which is what grading each proposition against the record exposes before a mediator does.

Then each disagreement gets priced. Hold every finding at the midpoint, swap one to the other side's number, and measure the swing. The top row here is the limitation clause, worth $420,373 against $184,600 for the entire lost-profits argument. Authority follows in two halves that are never summed without both being shown: exposure of $420,373 and $1,180,000 still to spend, so 73.7 percent of it is the price of finding out. Of 407,379 civil cases terminated in the year to September 2025, 1,681 reached trial.

A $1,200,000 line worth $18,711, and an authority number that is three quarters cost

The Damages Model, the Risk-adjusted Outcome Range, the Settlement Authority Note and the Mediation Brief.

Settlement and Mediation Brief Template
RiverDamages Model

Marbury Cold Chain v. Levanter Logistics  ·  prepared for the defence

Damages Model

The evidence columns are the point of the sheet. A component with an empty right-hand column falls out of the model on its own, without anybody having to argue about it.

ComponentClaimedEvidence that existsEvidence that does notNeeds
Spoiled cargo, invoiced value$1,240,000Invoices, rejection notices, reefer downloads, surveyor's reportNothing material3 findings
Cover freight at spot rates$612,000Carrier invoices for all 31 loads, the rate confirmationNothing ties 9 of the 31 loads to this breach4 findings
Lost profits, Hessling supply agreement$4,800,000The agreement, the termination letter, three years of margin historyNo renewal was executed, so two of four years are a forecast5 findings
Lost future customers$1,200,000Trade press coverage, one prospect declining to bidNo named account, no pipeline record, no comparator period4 findings
Prejudgment interest and costs$548,000The load dates and the statuteNot applicablepro rata
Total demanded$8,400,000Principal of $7,852,000, with interest attaching to whatever is actually recovered

One component is 57 percent of the demand

The lost profits claim carries two findings nothing else in the demand carries. It is the largest number on the sheet and the least supported one, and those two facts arrive together far more often than not.

Every row names the missing document rather than describing the evidence as thin. A named gap can be closed before the mediation and costed if it cannot. A general worry can only be argued about.

RiverOutcome Range

Risk-adjusted Outcome Range

Each component through its own chain, at three sets of estimates. Nothing here is a percentage of the total.

ComponentClaimedMarbury's chainMidpointLevanter's chain
Spoiled cargo$1,240,000$401,760$214,830$83,700
Cover freight$612,000$109,058$45,062$12,393
Lost profits$4,800,000$404,352$114,345$17,010
Lost future customers$1,200,000$58,320$18,711$2,430
Interest and costs, pro rata$548,000$67,941$27,425$8,063
Expected value of the claim$8,400,000$1,041,431$420,373$123,596
Share of the demand100%12.4%5.0%1.5%
The same claim on averaged findingscheck row$6,022,800$5,110,000$4,200,000

The components do not fall together, and that is the negotiation

The cargo loss is 15 percent of the demand and 51 percent of the value at the midpoint. The lost profits are 57 percent of the demand and 27 percent of the value. A blended discount on the total moves money between those two and flatters whoever proposed the blend.

The bottom row is the same claim with the common findings averaged rather than multiplied. At the midpoint the gap is $3,654,700, before any component gate is applied at all.

RiverAuthority Note

Settlement Authority Note

For the client conversation. Two halves, never summed without both on screen.

LineAmountWhat it is
Expected verdict exposure, midpoint chain$420,373The merits, discounted through every finding
Remaining defence costs to a verdict$1,180,000Discovery close, two experts, motion, pretrial, nine-day trial
Indifference point: pay up to this today$1,600,373Above it, settling costs more than fighting
Share of that number that is cost73.7%The finding, and it belongs in the first paragraph
Marbury's own chain, less its own costs$101,431What trying the case nets them at their best estimates
Zone of possible agreement$101,431 to $1,600,373Wide, and it closes if the clause goes Marbury's way

Sensitivity on the one finding that matters

Limitation clause atExpected valueAuthority to
15%$210,186$1,390,186
25%$350,311$1,530,311
35%$490,435$1,670,435
45%$630,559$1,810,559

Give a client a table and they have something to hold a view about. Give them one number and the only available responses are agreement and refusal, neither of which is a decision.

RiverMediation Brief

Confidential to the mediator  ·  not exchanged

Mediation Brief

The shared version and the confidential version are different documents. This is the second one, and it says so in its first line.

What is not in dispute

Eight loads moved under the master transport agreement between 4 March and 19 May. All eight recorded a temperature excursion in transit. All eight were rejected on arrival by the consignee. The invoiced value of the rejected product is $1,240,000 and neither party disputes the arithmetic.

Where the parties actually disagree, in order of what it is worth

#The findingWorthWhat would move it
1The limitation clause does not cap recovery at the freight charge$420,373A ruling. Nothing factual touches it
2Breach is Levanter's equipment rather than Marbury's loading$120,106The origin yard's own temperature record
3Lost profits recoverable at all$111,205A comparable account with documented margin

What the mediator is asked to do

Test the limitation clause with the other side before anything else. It is worth 2.3 times the lost-profits argument both parties came to have, and no amount of evidence exchanged today changes it.

Then find out whether the insurer is in the room, and on what terms. That question is not in the arithmetic and it decides whether a number in the zone can actually be paid.

Nothing said in a caucus goes into this file afterwards. Positions, amounts and dates only.

Edit with AI

What's in the pack

01

Damages Model

One row per component, with the amount, how it is computed, the evidence that exists, and the evidence that does not, named rather than described.

02

Issue Chain

Every finding as a proposition, which components it carries, both sides' probabilities with the basis for each, and the dollar value of the disagreement.

03

Risk-adjusted Outcome Range

Each component through its own chain at three sets of estimates, with the averaged figure alongside as a check row rather than as an output.

04

Mediation Brief

Structured from the sheets, in a shared version or a confidential one, with the same discipline about sourcing that a motion package needs.

05

Client Risk Memo

The expected value, why it is so far under the demand, the components that will not survive contact with the evidence, and what it costs to find out.

06

Settlement Authority Note

The number to ask for, split into exposure and remaining cost, with the concession order and the sensitivity table on the highest-swing finding.

07

What a Number Actually Assumes

The method behind all of it. Why a chain multiplies, why components fall by different amounts, and how the authority number splits in two.

How to use it

  1. 1

    Open in River, or take it blank

    Open the pack in River and hand it the demand, the pleadings and the damages evidence, or take the Word documents and CSV sheets from the template library.

  2. 2

    Components before any percentage

    Every part of the demand on its own row, with the computation and the document behind it, and every missing document named rather than summarised as a weakness.

  3. 3

    Write the findings, then ask for the probabilities

    One row per finding, phrased so it is either found or not found, with the components it carries. Both sets of numbers are asked for and never generated.

  4. 4

    Multiply, rank, then split the authority

    Run the chain three ways, sort the findings by what disagreeing about each is worth, and report exposure and remaining cost as two separate lines. The second line comes off the priced calendar in the litigation status and client reporting pack, which already splits remaining cost into what can be estimated and what depends on a ruling nobody has yet.

Frequently asked questions

Is this template free?

It is, with no account and no card. The zip holds four Word documents and three CSV sheets. Edit with AI is the other route: the agent fills the sheets from your record and asks for the one thing it will not produce. Everything in the template library works the same way.

What format are the downloaded files?

Word (.docx) for the brief, the risk memo, the authority note and the method doc, and CSV (.csv) for the three sheets, in one zip. Excel, Numbers or Google Sheets opens the sheets directly. Nothing is proprietary and there is no conversion step.

Where do the probabilities come from?

You. Every probability cell stays blank until a lawyer writes a number in it, and nothing in the pack will generate one. That number is the only judgement in the exercise, and a figure produced to fill a column would launder an opinion into arithmetic that then looks objective.

Why estimate what the other side believes?

Because the ranking needs two numbers per finding to produce a swing, and the swing is what tells you which argument is worth the afternoon. Infer their estimate from behaviour rather than rhetoric: what they briefed, what they moved on, and what they never bothered to depose.

Can what happens in the mediation be used later?

Largely not. Compromise offers, and conduct or a statement made during compromise negotiations, are inadmissible to prove or disprove the validity or amount of a disputed claim. The pack still records positions, amounts and dates only, because a working file of caucus conversation helps nobody.

Does it tell me whether to make a formal offer?

No, and that is deliberate. A defending party can serve one at least 14 days before trial. If the judgment the offeree finally obtains is not more favorable than the unaccepted offer, the offeree must pay the costs incurred after the offer was made. The pack gives you the exposure and the cost. The tactic is yours.

What does Edit with AI actually do?

It signs you up, installs this pack as a private workspace, and puts the agent in front of an empty Damages Model. Send the demand, the pleadings and the damages evidence. What comes back first is the list of components with nothing behind them, and the authority on any clause that decides one.

Sources

  1. U.S. Courts1,681 reached trial (opens in a new tab)
  2. U.S. CourtsFederal rules of evidence (opens in a new tab)
  3. U.S. CourtsFederal rules of civil procedure (opens in a new tab)

Written by

Chandler Supple

Co-founder & CEO, River

Chandler has spent the last six years working in AI, building tools for millions of users and Fortune 100 companies. In 2025, he co-founded River to build a new kind of operating system for AI agents.

LinkedInGitHubX

Reviewed by

Brian Joseff, Co-founder, River

LinkedInX

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Take the demand apart before anybody argues about it

Take the Word documents and CSV sheets blank, or open this exact pack in River and hand it the demand and the record.

Edit with AI