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P1431 REVIEW DENIED An agreement signed by all parties at the start of mediation providing that everything that took place at mediation would be protected from discovery, except as may be necessary to enforce any agreement resulting from the mediation, brings a settlement agreement reached after the disclosure agreement was signed within an exception to the mediation privilege created by Evidence Code section 1123; a chart prepared in mediation and initialed by all parties may qualify as a settlement agreement.CitationEst of THOTTAM v THOTTAM (Mediation Chart) 165 CA4 1331 [See: EvC 1119, 1123; Simmons v Ghaderi 44 C4 570, P/AT 9/08]
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