“Something is better than nothing.” Usually true when it comes to a mediation statement. I would rather receive some information rather than no information before commencing a mediation. In the past, I have received “canned” statements, a copy of a parties simple complaint or a single pleading.
On the other end of the spectrum, I have received multiple depositions, complete “pleading” folders or binders and binders of exhibits. I am not complaining - again, something is better than nothing!
However, there are three items which are frequently omitted in position statements that I believe are helpful and warranted for inclusion: