rmits and encourages counsel to discuss matters in an uninhibited fashion often leading to settlement ...." Id. at 930. Ten years later, in Folb v. Motion Picture Ind. Pension & Health Plans, 16 F. Supp. 2d 1164, (C.D.Ca. 1998), the district court in California became the first federal court to adopt the mediation privilege as federal c

nt of everything that transpires during mediation . . . . Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.1979); Folb v. Motion Picture Ind. Pension & Health Plans, 16 F.Supp.2d 1164, 1173 (C.D.Ca. 1998); Sheldone v. Pennsylvania Turnpike Comm n, 104 F.Supp.2d 511, (W.D.Pa. 2000); Microsoft Corporation v. Sun

its and encourages counsel to discuss matters in an uninhibited fashion often leading to settlement . . . ." Id. at 930. Ten years later, in Folb'. Motion Picture Ind. Pension & Health Plans, 16 F. Supp. 2d 1164, (C.D.Ca. 1998), the district court in California became the first federal court to adopt the mediation privilege as federal c