Friday, February 06, 2009 3:30:09 PM
(12) The possibility of early mediation
Plaintiffs believe that early mediation would be productive based on the long-standing
dispute between the parties pending in the United States District Court for the Southern District
of New York and the parties past, productive efforts at reaching an agreed settlement of that
action. Plaintiffs expect that any such mediation would encompass both that action and this
action. Defendant does not necessarily disagree, but the track record on attempts at settlement in
the past is not good.
"A man doesn't know what he knows until he knows what he doesn't know"
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