T2 Mediation Plan

1. Mediation Strategy:
The primary objective of the mediation is to resolve existing differences and reach a
collaborative solution. The competing party will use the mediation process to alleviate the
distress caused by the privacy breach as well as the financial troubles faced by the client and
her guardian. The primary strategy is to use, as leverage, the fact that the client will most
certainly win the ZEE Hunt and consequently own 80% stake in Ashbook Gaming Company
(“Ashbook”). The idea is therefore to share the rewards of the ZEE Hunt with the opposing
party in exchange of financial support and active measures to tackle the issue surrounding
breach of privacy. Such a strategy would ensure a win-win situation as owning some stake in
Ashbook is essential for the survival of the opposing party at this point in time. Further, the
opposing party taking measures to tackle the breach of privacy, will help build trust between
the parties. This, in turn, will build a strong foundation for the smooth working of Ashbook in
the future.
2. Division of Responsibilities and Tactics between Client and Counsel:
Client: The client will be responsible for setting the tone for the mediation by bringing out the
narrative of the problem from her perspective. She will ensure that her interests are clearly
communicated to the opposing party. Discussion on interests vis-à-vis breach of privacy,
winning the ZEE Hunt, retaining majority stake in Ashbook and discretionary power over the
finances of Zeta, will be initiated by the client. This is because she is in the best position to
explain these aspects of the dispute as they originate from her participation in the ZEE Hunt.
She will also ensure that there are no communication gaps between the parties. She will
communicate candidly and precisely, and also promptly clarify, and ask questions in case of
discrepancies. This will help the parties have an open dialogue and facilitate the mediation. It
will also help the parties generate creative solutions. The client will ensure that the solutions
she proposes, or agrees to, align with her interests.
Counsel (Guardian): The discussion on seeking the opposing party’s help for payment of the
client’s college accommodation fees and repayment of her parents’ debt will be ideally initiated
by the guardian. This is because these interests ensue from her position as the client’s guardian
and her lack of finances to support the client. As her guardian, her primary responsibility lies
in guiding the discussion in the client’s interest. This can be ensured by encouraging a clear
and collaborative dialogue between the parties, rather than a debate over the issues. This can,
in turn, be ensured by asking open ended and clarificatory questions and making timely use of
the mediator. The guardian will also advise the client on the financial aspects of the dispute.
She will concretize the client’s solutions and ensure that they are viable. The guardian will

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 T2 Mediation Plan

ensure that the parties effectively communicate during, and attempt to break through any
impasse; while always prioritizing the client’s interests.
3. Competing Party’s Underlying Interests:
• Obtaining a solution/damage control for the breach of privacy, by way of technical support
from Astroworld (such as, deletion of her personal details from the Zetaverse, controlling
the media coverage of her identity) and/or monetary damages.
• Retaining majority of the winning share in Ashbook (at least 40%) and discretionary
powers over the finances of Zeta.
• Obtaining financial support from the opposing party for payment of the client’s college
accommodation fees and repayment of her parent’s debt.
• Securing Tyler’s help in investigating Ashanti’s death.
4. Competing Party’s BATNA and WATNA:
• BATNA: Initiate court proceedings against Travis Scooter and Astroworld for breach of
privacy and claim compensation for the same. Also report Travis Scooter and the Astros to
Ashbook and seek their disqualification from the ZEE Hunt. Further, after winning the third
game of the ZEE Hunt, use the 80% stake in Ashbook to repay the debt, pay for college
accommodation and hire a management team to run Ashbook.
• WATNA: File a suit against Travis Scooter and Astroworld for breach of privacy and
receive an unfavourable verdict. Further, end up losing the third game of the ZEE Hunt and
consequently the 80% stake in Ashbook, leading to compounding of financial troubles.
5. Opposing Party’s Interests and BATNA:
Interests:
• Gaining ownership of Zeta by persuading Megan to represent Astroworld in the ZEE Hunt,
as winning the ZEE Hunt could potentially resolve Astroworld’s financial troubles.
• Avoiding a potential law suit for breach of privacy and disqualification from the ZEE Hunt
since Astroworld is facing severe losses.
• Restoring Travis’ personal and Astroworld’s corporate reputation that could potentially be
further damaged due to Megan’s threat of a law suit for breach of privacy by either working
collaboratively with Megan on Zeta or issuing a public statement clarifying the incident.
BATNA: Win the ZEE Hunt by either a) striking a deal with qualifiers, other than Megan, to
participate on Astroworld’s behalf; or b) one of the 10,000 Astros obtaining the three keys and
subsequently the egg. Successfully defending the suit for alleged breach of privacy, if filed by
Megan, and avoiding disqualification of Astros from the ZEE Hunt.