Written ENE Statements (a) Time for Submission. No later than 7 days before the first ENE session unless otherwise directed by the Evaluator, each party must submit directly to the Evaluator, and must

(b) Prohibition Against Filing. The statements constitute confidential information as defined in ADR L.R. 5-12, must not be filed and the assigned Judge shall not have access to them. (c) Content of Statement. The statements must be concise, may include any information that may be useful to the Evaluator, and must, unless otherwise directed by the Evaluator: (1) Identify, by name and title or status: USDC ADR Local Rules – Effective May 1, 2018 ADR-11 (A) The person(s) with decision-making authority, who, in addition to counsel, will attend the ENE session as representative(s) of the party, and (B) Persons connected with a party opponent (including an insurer representative) whose presence might substantially improve the utility of the ENE session or the prospects for settlement; (2) Describe briefly the substance of the suit, addressing the party’s views of the key liability issues and damages and discussing the key evidence; (3) Address whether there are legal or factual issues whose early resolution would reduce significantly the scope of the dispute or contribute to settlement negotiations; (4) (5) Identify the discovery that is necessary to equip the parties for meaningful settlement negotiations; and Include copies of documents out of which the suit arose (e.g., contracts), or whose availability would materially advance the purposes of the Evaluation session, (e.g., medical reports or documents by which special damages might be determined).