Mediation Notice may include the following:
1. The Applicant wish to attempt mediation to resolve all of their disputes with the respondent namely, all the claims of ....., including proceedings ...... and any applications or interlocutory relief, including for ......, and make the following proposal.
2. The Applicant proposes to adopt the Mediation Rules of the Hong Kong International Arbitration Centre for the mediation.
3. The Applicant proposes to appoint …. as the mediator. The CV of the mediator is attached. The estimated costs rates for engaging …. is as follows respectively,
4. The Applicant proposes Hong Kong International Arbitration Centre or some other venue to be mutually agreed by all parties in consultation with the mediator as the venue for the mediation. The estimated costs of renting the venue for the mediation are HKD1200 half day / HKD1900 full day for a room of 6-8 person in Hong Kong International Arbitration Centre (subject to the latest changes in charge as published from time to time).
5. The Applicant makes the following proposals as to payment of fees and costs for mediation and whether the same could be recoverable as costs of the proceedings if mediation fails: ......
6. The Applicant proposes that the mediation should commence as......
7. (Optional) The Applicant requests an interim stay of the legal proceedings herein for ….. days form commencement of and pending the mediation process.
8. (Optional) The Applicant’s willingness to pursue mediation is conditional upon an interim stay of legal proceedings being granted.
Dated this …... day of ………