---
title: "Prepare a mediation summary for the client from the file"
url: "https://ailawframework.com/practice/arbitration-and-alternative-dispute-resolution/prepare-a-mediation-summary-for-the-client/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A6-B7-5-US"
practice_area: "Arbitration & Alternative Dispute Resolution"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Prepare a mediation summary for the client from the file

> From the pleadings and the documents the lawyer marks, list the amounts claimed, the amounts offered in writings already in the file, and the issues still open.…

Canonical page: https://ailawframework.com/practice/arbitration-and-alternative-dispute-resolution/prepare-a-mediation-summary-for-the-client/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Arbitration & Alternative Dispute Resolution](https://ailawframework.com/practice/arbitration-and-alternative-dispute-resolution.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | From the pleadings and the documents the lawyer marks, list the amounts claimed, the amounts offered in writings already in the file, and the issues still open. Do not write a paper to send to the mediator or the other side. |
| What the lawyer must review | Federal Rule of Evidence 408(a) excludes, when offered to prove or disprove the validity or amount of a disputed claim or to impeach by a prior inconsistent statement or a contradiction, evidence of furnishing or accepting a valuable consideration in compromising a claim, and conduct or a statement made during compromise negotiations about the claim, with the criminal-case exception the rule states. Rule 408(b) allows admission for another purpose, such as proving bias, negating a contention of undue delay, or proving an effort to obstruct a criminal investigation. Rule 408 is not a mediation privilege. Rule 1.6 and Formal Opinion 512: the client’s numbers stay in a confidential tool. The lawyer writes anything the client will see as advice. |
| Written for | United States |
| Applies to | [Prepare a mediation summary for the client](https://ailawframework.com/practice/arbitration-and-alternative-dispute-resolution/prepare-a-mediation-summary-for-the-client.md) |

## Checking plan

- What the AI does: From the pleadings and the documents the lawyer marks, list the amounts claimed, the amounts offered in writings already in the file, and the issues still open. Do not write a paper to send to the mediator or the other side.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- State mediation-confidentiality statutes were not opened. Do not treat Rule 408 as a promise that a mediation statement cannot be disclosed.
- The summary is for the lawyer’s discussion with the client. It is not a mediation brief.

## Sources

- [Federal Rule of Evidence 408, compromise offers and negotiations](https://www.law.cornell.edu/rules/fre/rule_408) (checked 2026-10-22)
- [ABA Model Rule 1.6, Confidentiality of Information](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_6_confidentiality_of_information/) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*