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299. See Sheldone v. Pa. Turnpike Comm'n, 104 F. Supp. 2d 511, 515 (W.D. Pa. 2000) (recognizing, in non-FOIA case, privilege for communications arising from mediation process); Folb v. Motion Picture Indus. Pension & Health Plans, 16 F. Supp. 2d 1164, 1180-81 (C.D. Cal. 1998) (holding, in non-FOIA case, that federal mediation privilege protects all communications exchanged in course of formal mediation proceeding), aff'd, 216 F.3d 1082 (9th Cir. 2000) (unpublished table decision); cf. 28 U.S.C. Â 652(d) (2000) (requiring district courts to provide by local rule for confidentiality of alternative dispute resolution proceedings); 5 U.S.C. Â 574(j) (2000) ("A dispute resolution communication which is between a neutral and a party and which may not be disclosed under this section shall also be exempt from disclosure under section 552(b)(3).").

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