Question 1 of 10
Your client is defendant in a breach of contract dispute. The dispute is being mediated and he has the following documents with him:a position paper drafted by his solicitor for the purposes of mediation;the contract which is the subject of the dispute;an internal risk management report created for the purposes of seeking advice from his solicitor on possible litigation; anda draft witness statement prepared for the purposes of the claim and not yet disclosed or provided to the claimant.Which ONE of the above documents is most likely to be protected by without prejudice privilege?