I would like to be addressed as MR. Shantanu , Manager of widget co.

yes I have
the full authority to take any decision on behalf of my company.
Firstly I would like to thank both the mediators for organizing this mediation
session and provides us a platform on which we can minutely express our
concerns. I am expecting this to be a very fruitful session ahead for both the
parties. And I am expecting an impartial decision in the end of this session. I
would also thank mr. and their counsel for agreeing to resolve this issue amicably.
I am the manager of widget co. nd I would like to present my issues or concerns
here.
We r one of the leading manufacturer of high quality widgets (which is basically a
mechanical device) used in several industries.
We entered into a contract with the gadget corp for 1 yr and following are the
relevant details of said contract;
1) Our co. agreed to supply 5000 widget per month @ 10 per widget
2) It has been agreed between us that gadget corp can cancel the contract but
only with the prior notice of 30 days.
3) However gadget corp rescinded the contract in just 6 months before the
maturity period with disobeying the t&c of the contract.
4) This act of gadget corp was ultra vires of the agreed terms and conditions
of contract and costs us heavy losses as we left with a surplus of 2000
widgets and also deteriorate our reputation the market.

So like to summarise our Issues. We have majorly 3 points

1) Execution
2) Compensation
3) Prolonged future colloboration
 First one is execution which mainly caters to non-performance of the
said contract by the gadget corp. like this is very unprofessional to
breach the contract at this point of time and that too without the
prior notice as mentioned in the clauses of the contract.
  Second would be compensation of 30000 dollar which we are seeking
for damages caused to us due to this unfair behavior of the
responding party.

 And the last one would be that is there any chance of future
collaboration we can expect from gadget corp. if we mutually arrive
at any decision.

Counters:
I just want to confirm one thing from Mr.gadget corp and plz try to clearly specify
that after how many months or time u were started to receiving this abnormal
size of widgets. And have u made any effort to convey this issue to our
organization because there is no any justification for not serving the notice.
1) I am not fully satisfied with the response from Gadget corp because I am
not able to understand this point that If there were any discrepancies in the
size of widgets then you should have atleast disseminate this thing to us by
using proper channel of communication. The reason for cancelling the
contract without any notice is not justified here.

2) HOWEVER, What I have deduced from this session till now is that this all
happened due to miscommunication from both the sides and we are here
for a mutually benficial agreement in the end of this session,

So our proposed plans would be :

 Setting up a proper channel of Communication for future
collaboration
 A fair compensation should be paid to us for repair of our losses
 Completion of the remaining contract of 2000 widget

Call for a Caucus

Thank u so much counsel for highlighting the manner in
which we could negotiate however I am bit unclear about
 the statements you made so I would request the mediators
to call a caucus.

CAUCUS:
I would like to draw ur attention towards this that we r a
profit driven company and we want both of the parties to
progress alongside so I think it would be very reasonable if
they firstly complete the remaining contract in given period
and we will give them assurance regarding the standards of
product in writing . Secondly we r just seeking a fair
compensation of around 5% of total contract value which is
30000 dollar however we can forego this compensation if
they agrees to pay us 10000$ as well as execution of the
remaining contract. We want to continue our business
relations with Gadget corp and therefore we r looking for
solutions here.
Like 10000 dollar which we r seeking is basically to
compensate our lost reputation in the market.

CLOSING STATEMENT
Firstly I would like to thank the mediators for helping and
guiding us to raises our concerns and reaches us to mutual
beneficial decision. Also I would like to take this opportunity to
thank Gadget corp and their counsel for extending their
cooperation throughout this mediation process. I wish best of
luck to them nd looking forward to have future collab with you.
Thank u. now over to my counsel.