Marshall Petersen filed a lawsuit against the grape producer, alleging various breaches of contract; however, the court in which he filed suit has a mandatory mediation program that requires all litigants to attempt to settle their cases outside of court before trial will be scheduled. Marshall must now draft a confidential mediation memo that states his legal and factual positions about the issues in dispute. This memo will be confidential (not shared with the grape producer), so Marshall needs to provide the mediator with sufficient background to facilitate a settlement between the parties.