_______________, referred to as the 1st PARTY, and __________________, referred to as the 2nd PARTY, agree:
A dispute has arisen. The parties herewith agree that each shall forego litigation of the dispute until the date of _____________, and shall submit the dispute to mediation under the terms and conditions set forth herein.
The parties agree that during the period of mediation, and for a period of 30 days after impasse of mediation is declared, the statute of limitations shall be tolled. Provided, however, that any party may assert as a defense that any statute of limitations or other form of issue preclusion through lapse of time which occurred prior to this agreement may be plead and litigated should there be an impasse and litigation ensue.
The parties select ___________________ to act as the Mediator….
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